The transfer of Exor and of Giovanni Agnelli & C to the Netherlands will have important implications on the control of the holdings, particularly on Exor. The plan, which will be subject to the shareholders’ approval on 3 September, provides that each Exor ordinary share owned continuously for five years will entitle to five voting rights at the end of this term. Should the ownership be extended to 10 years, the voting rights for each share will be 10. With this action, the Agnelli family, which will certainly keep the holding’s shares for a long time, can sell Exor shares on the market in the future without risking losing control on it. But what are the tax consequences of this operation for the family and, particularly, on the Italian Inland Revenue? “First of all, it is true that this operation was not devised for tax reasons, but due to the regulatory environment” explains Alessandro Dragonetti, managing partner and head of tax at Bernoni Grant Thornton.
