Immediate Group VAT Access for Newly Established Company Beneficiary of Corporate Split

• The Italian Revenue Agency examined a corporate reorganization involving a subsidiary under the group VAT regime.
• In 2024, the subsidiary underwent a partial proportional demerger, transferring part of its assets to a newly established beneficiary.
• Before the reorganization, the parent company controlled 80 percent of the demerged company, and post-reorganization, it controlled both the demerged and the new beneficiary at the same percentage.
• The parent company inquired about including the new beneficiary in the consolidated VAT liquidation starting in 2025, bypassing the requirement of control from July 1 of the previous year.
• The Agency confirmed the inclusion of the new beneficiary from 2025, as there was no interruption in control, and the group VAT perimeter remained unchanged.
• The new beneficiary continued the commercial activity of the demerged company and was controlled by the parent company at over 50 percent.

Source: eutekne.info

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.

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