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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.

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