With the replies to ruling no. 91 of January 19, 2023 and No. 157 of January 24 2023, the Italian tax authorities provided clarifications on the treatment applicable for VAT purposes (and, in reply to ruling no. 91, also for registration tax purposes) to the transfer of assets existing in the territory of the State forming part, respectively, of a partial demerger and a merger by incorporation occurred abroad between companies resident in European Union without a permanent establishment in Italy.
Source PwC
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