Participation Exemption and Foreign Entities: How Far Can Judicial Interpretation Go?

Journal
Morri, S.; Guarino, S.
Italy
European Taxation 2017 (Volume 57), No. 5
Format/Price
JournalUSD 45

The authors of this note discuss the decision of the Regional Tax Court of Abruzzo in Decision No. 1477 of 28 September 2015, wherein the Court extended, by way of interpretation, the more favourable capital gains tax regime applicable to domestic companies to gains realized by a French company.