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VAT Group: Acquisition of Control and Merger Trigger Financial Link in Another VAT Group

  • ALFA acquired control of BETA in 2025 through a public takeover offer, and a broader integration plan includes BETA’s merger into ALFA effective 20 April 2026.
  • ALFA is the representative of VAT Group ALFA (since 1 January 2019), while BETA is the representative of VAT Group BETA (since 1 January 2025).
  • The question concerns when the “financial link” required for VAT group membership is considered to arise under Article 70-quater, paragraph 5, of Italian VAT law.
  • The rule states that if a financial link arises after the VAT group option was exercised, the relevant entity joins the VAT group from the year after the link is established.

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.



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