Comparative Guides

Welcome to Mondaq Comparative Guides - your comparative global Q&A guide.

Our Comparative Guides provide an overview of some of the key points of law and practice and allow you to compare regulatory environments and laws across multiple jurisdictions.

Start by selecting your Topic of interest below. Then choose your Regions and finally refine the exact Subjects you are seeking clarity on to view detailed analysis provided by our carefully selected internationally recognised experts.

4. Results: Answers
Corporate Tax
Is tax consolidation permitted, on either a tax liability or payment basis, or both?

Answer ... Two different tax consolidation regimes are optionally applicable in Italy:

  • a domestic consolidation regime, including only Italian controlled companies; and
  • a worldwide consolidation regime, including both Italian and foreign controlled companies.

In both cases, the tax group determines a single taxable basis for corporate income tax (‘Imposta sul Reddito delle Società’) purposes, determined the sum of the taxable bases of the companies included within the tax consolidation perimeter. In this respect, while the domestic tax consolidation regime implies that not all Italian subsidiaries must be consolidated (‘cherry-picking’ mechanism), the worldwide tax consolidation regime implies that all subsidiaries must be consolidated (‘all-in’ mechanism).

For more information about this answer please contact: Guido Lenzi from Puri Bracco Lenzi e Associati