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News & Analysis

Franco Pozzi and Simona Zangrandi of Biscozzi Nobili & Partners examine secondary transfer-pricing adjustments under Italian tax practice

06 March 2026 by Studio Legale e Tributario Biscozzi Nobili & Partners - Italy

With judgment No. 4699 of November 26, 2025, the First Instance Tax Court of Milan ruled that, under the combined provisions of the Italy-Switzerland Double Taxation Treaty and OECD Commentary (paragraph 12.25), payments exceeding the arm's length value are not taxable as “royalty” in Italy.
News & Analysis

Dividend exemption

24 November 2025 by Studio Legale e Tributario Biscozzi Nobili & Partners - Italy

Is the Italian dividend exemption set to partially disappear? Franco Pozzi and Gloria Strappa of Studio Biscozzi Nobili and Partners discuss on proposed amendments of Italian taxation of dividend under 2026 Budget Law.