The tax benefit aimed at facilitating the assignment and transfer of movable and immovable assets registered in public records to shareholders is substantially relevant for income tax purposes. However, it can have also VAT implications, though VAT itself is not concerned by the tax benefit. The Italian Revenue Office provided some clarifications on this issue in circular letters no. 26/E dated 1 June 2016 and no. 37/E dated 16 September 2016. Nonetheless, there are still some unresolved issues concerning the accomplishments to be fulfilled by taxpayers subsequently to the exclusion of the abovementioned assets from the corporate assets, pursuant to the close relationship between direct and indirect taxation.
