Publications
22/12/2025
Rischio di repricing con effetti sull'hedge accounting. Lo IASB propone di introdurre un modello di mitigazione del rischio
Luca Malfatti
Compliance, Tax Law
Aerospace, Automotive, Finance
13/07/2026
The IASB clarifies which entities may apply the IAS 28 fair value option to investments in associates and joint ventures, also addressing its interaction with IFRS 18.
30/06/2026
The article examines the impact of the Swiss participation reduction on the Italian CFC regime, focusing on the comparison between the foreign effective tax rate and the Italian domestic virtual tax rate. Although technically different from the Italian participation exemption, the Swiss regime may, in principle, qualify as fiscally equivalent where participation-related costs are fully neutralised for tax purposes. The assessment nevertheless requires a case-by-case analysis of the cost structure, the type of holding company and the composition of its income. The impact of the Swiss participation deduction on the Italian CFC regime
27/06/2026
The article examines the practical issues raised by the €750 million Global Minimum Tax threshold for groups operating under long-term contracts. Different accounting treatments of work in progress may shift or concentrate revenue across financial years, distorting the threshold calculation. The authors therefore call for a broader review of the concept of “revenue” for GMT purposes.
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