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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.
News & Analysis

Massimo Foschi of Studio Biscozzi Nobili & Partners deals with the main tax feature of the divisions by spin off (“scissioni con scorporo”)

01 April 2025 by Studio Legale e Tributario Biscozzi Nobili & Partners

Divisions are tax-neutral (non-recognized) transactions under Italian tax law, that do not give rise to taxable gains or deductible losses on the assets of the companies involved
News & Analysis

Franco Pozzi and Luca Consalter of Studio Biscozzi Nobili and Partners discuss on recent case law in respect to free interest intercompany loans and how taxpayers can support said agreements under domestic transfer pricing principles

31 March 2025 by Studio Legale e Tributario Biscozzi Nobili & Partners

The treatment of interest-free intercompany loans under Italian transfer pricing practice evolved with conflicting interpretations