Transfer of Business Branch between Italian Organizations of Foreign Multinational Groups – VAT and Registration Tax Treatment

• The Italian branch of a foreign company, Alfa, is requesting clarification on the VAT and registration tax treatment of a business transfer.
• Alfa is part of the multinational group Beta and was established in September 2022 for the purpose of the described operation.
• The transfer involves the transfer of the entire business activity of the Italian branch of Gamma Bank to two newly established Italian branches of Beta Group.
• After the transfer, Gamma Bank will maintain its presence in Italy but will not be able to engage in any activities immediately.
• The transfer includes highly qualified employees, contracts, assets, customers, and goodwill, with a consideration of approximately $1.5 million.
• Alfa intends to continue the acquired business activity with the same organizational structure and identity.
• Alfa is seeking clarification on the territoriality of VAT and the application of the VAT neutrality regime and a 3% registration tax rate.

Source: agenziaentrate.gov.it

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.

---

---