- The document is a response from the Division of Taxpayers, Central Directorate for Large Taxpayers and International Affairs, regarding an inquiry about VAT Group.
- The inquiry (Response No. 228/2024) concerns the absence of an “organizational link” between companies ALFA and BETA under Article 70-ter of the Italian VAT Decree.
- ALFA, as the representative, established the ALFA VAT Group on January 1, 2022, which includes companies x, y, and z.
- ALFA acquired full ownership of DELTA, a holding company in liquidation, and gained control over its subsidiaries, including BETA.
- According to Article 70-decies of the VAT Decree, all companies in the DELTA Group undergoing liquidation are excluded from the VAT Group, except for BETA.
- ALFA leads a financial sector group, while BETA is part of the DELTA Group, which operates mainly in the organized large-scale distribution sector.
- The DELTA Group structure includes DELTA1 as the Italian sub-holding, which owns DELTA2 and a majority of DELTA3, with DELTA2 holding shares in BETA.
- BETA primarily engages in real estate construction and trading.
- In 2020, the DELTA Group faced financial difficulties exacerbated by the COVID-19 pandemic, leading to debt restructuring efforts.
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.
