Technical News – July 2023

© Jacob Dahgren


  • Main new developments in case-law:
Court Tax  Link  Take-away
CAAD CIT Here Expenses with tolls, car parks and car parks are not subject to autonomous taxation in IRC.
TCA CIT Here The correct completion of the Form 21 RFI makes it presumed that the beneficiary of the income is the UBO, and it is up to the PTA to prove the contrary (namely by using the exchange of information).
STA PIT Here Taxpayers with activities falling under the code “CIRS 15-Other activities exclusively of provision of services” are subject to the fixing of the tax base by the coefficient 0.75 in the simplified regime.
STA PIT Here In the sale of shareholdings with a price adjustment clause, the capital gain is calculated taking into account the final price (with the negative or positive adjustment) if it is already known, even if it has not yet been paid.



  • Main news in terms of legislation and AT information:
Legislation Tax Link Take-away
PIV RETT Here The acquisition of the bare ownership of
autonomous fractions for resale may benefit from the IMT exemption for purchase for resale operations.
PIV RETT Here The mere change of a rustic building into an urban building does not cause the exemption from IMT for purchase for resale operations to expire.
PIV PIT Here The prize obtained in a scientific thesis competition may be subject to IRS (Category B) if the competition involves the temporary or definitive assignment of the respective copyright.
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