Ruling 529: Dynamic holding company – VAT deduction Transaction cost

ALFA (hereinafter, the “Company” or the “Applicant”) was incorporated on
… as part of the acquisition process that resulted in the transfer
control of the company BETA from private equity fund X to private equity fund
equity fund Y (hereinafter, Fund Y).
The acquisition of BETA by Fund Y (hereinafter,
the “Acquisition”) was finalized on … through the special purpose vehicle (c.d.
Special Purpose Vehicle) ALFA1, wholly owned by the Applicant, which is in turn
wholly owned by the company GAMMA, indirectly controlled by the Fund
Y.
Specifically, as represented in the petition, the transaction was
been carried out by acquiring from the selling party the ownership of the chain
controlling interest in BETA consisting of five holding companies under foreign law
foreign law and one holding company under Italian law (the “Intermediate Holding Companies”).
As a result of the Acquisition, the Applicant indirectly controls BETA
through an equity chain represented by the Intermediate Holding Companies.

Source: gov.it

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