The new Incentives Code 2026

Il nuovo Codice degli Incentivi 2026: verso un sistema organico, digitale e trasparente per la crescita delle imprese

Author

IPG, Marco Palestro, Tommaso Perri

Activity area

Tax Law

Il_nuovo Codice degli Incentivi 2026_pdf.pdfOpens in a new tab

IPG Journal

25/08/2026

THE NEW ARTICLE 2394-BIS OF THE ITALIAN CIVIL CODE: INITIAL INTERPRETATIONS

The analysis examines the new Article 2394-bis of the Italian Civil Code, as amended by Legislative Decree No. 47/2026, which introduces a two-year time limit for bringing liability actions in insolvency proceedings. Particular attention is paid to the nature and starting point of the new time limit, its scope of application, transitional issues and the challenges arising from its coordination with the Italian Crisis and Insolvency Code. The new article 2394-bis of the italian civil code: initial interpretations

13/07/2026

Associates and joint ventures measured at fair value

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 impact of the Swiss participation deduction on the Italian CFC regime

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

IPG Journal