-
Transactional advisory services
Find out more about the transactional advisory services of Grant Thornton Financial Advisory Services
-
Valuations
Find out more about the valuations services of Grant Thornton Financial Advisory Services
-
Mergers and acquisitions
Find out more about the merger and acquisition services of Grant Thornton Financial Advisory Services
-
Forensic and investigation services
Find out more about the forensic and investigation services of Grant Thornton Financial Advisory Services
-
Recovery & reorganisation
Find out more about the Recovery & reorganisation services of Grant Thornton Financial Advisory Services
-
Business risk services
Find out more about the business risk services of Grant Thornton Financial Advisory Services
-
Business consulting
Find out more about the business consulting services of Grant Thornton Financial Advisory Services
-
Capital market
Capital market
-
Corporate and business tax
Find out more about our corporate and business tax services.
-
Direct international tax
Find out more about our direct international tax services.
-
Global mobility services
Find out more about our global mobility services.
-
Indirect international tax
Find out more about our indirect international tax services.
-
Transfer pricing
Find out more about our transfer pricing services.
-
Litigation
Our lawyers and accountants can manage all defense measures provided not only by the Italian law, but also by EU regulations and conventions
-
Family business
Find out more about our Family business services.
-
Legal
The client can be assisted in every need and with the same care both on important operations or disputes and on simple matters
-
Back office outsourcing
Find out more about our Back office outsourcing services
-
Business process outsourcing
Find out more about our business process outsourcing services.
-
Compilation of financial statements
Find out more about our compilation of financial statements services.
-
Tax compliance
Find out more about our tax compliance services.
-
Electronic invoicing
Find out more about our electronic invoicing services
-
Electronic storage
Electronic storage is an archiving procedure that guarantees the legal validity of a digitally stored electronic document
-
Revaluation of corporate assets
Find out your civil and fiscal revaluation of tangible, intangible and financial assets
-
Human resources consulting
Find out more about our human resources consulting services.
-
Payroll
Find out more about our payroll services.
-
HR News
HR News the monthly information newsletter by Grant Thornton HR
-
Cybersecurity
GT Digital helps clients structure information security management internal functions, also through partially or totally outsourced functions
-
Agile and Programme Management
GT Digital provides support in the adoption and implementation of different portfolio management
-
Robotic Process Automation
Our “BOT Farm” can rely on digital workers able to help clients in routine activities, allowing employees to deal with more added-value activities
-
Data strategy and management
GT Digital can support clients in seizing the opportunities offered by Big Data, from the definition of strategies to the implementation of systems
-
Enterprise Resource Planning
We support clients in selecting the most appropriate ERP System according to their specific needs, helping them also understand licensing models
-
IT strategy
GT Digital supports clients in making strategic choices, identifying innovation opportunities, comparing themselves with competitors
-
IT service management
We can support with software selection and with the implementation of dedicated tools for the management of ICT processes
Paragraphs 1122 and 1123 of art.1 of Budget Law 2021 (Law no. 178/2020) reintroduce the possibility to revaluate the purchase cost of participating interests that are not traded on regulated markets and of buildable and agricultural land being held at 1st January 2021.
Below is an outline of the main characteristics of the measure.
Subjects concerned
The following subjects can benefit from the allowance under analysis:
- individuals, for transactions that do not fall within the performance of the business activity;
- partnerships and comparable subjects;
- non-commercial entities, if the transaction that generates income does not fall within the performance of the business activity;
- non-resident subjects, as concerns capital gains deriving from the sale of participating interests in companies residing in Italy, which are not referable to permanent establishments.
Subjects perceiving corporate income are excluded.
Requirements, fulfilments and substitute tax
The requirements to benefit from this favourable measure can be summarized as follows:
- Revaluated participating interests and land must be already held at 1st January 2021;
- A qualified professional (e.g. chartered accountant) must prepare and swear the proper expert’s appraisal of the value of the concerned participating interest and/or land by 30 June 2021;
- The concerned taxpayer must pay a 11% substitute tax by 30 June 2021 according to the following payment terms.
Payment terms
The substitute tax can be paid in a single payment by 30 June 2021 or in three equal annual instalments. In the latter case, the first instalment is due by 30 June 2021, while remaining instalments will be due, respectively, by 30 June 2022 and 30 June 2023. The instalment payment of tax implies an increase by 3% as interest, to be charged on an annual basis starting from 30 June 2021.
Calculation of the economic advantage
The option for the revaluation of participating interests must be preliminarily carefully evaluated, in order to define its exact economic advantage in case of a future transfer of such interests.
In fact, in order for this allowance to bring an actual economic advantage, the 11% substitute tax – to be applied on the whole revaluated value of the participating interest – must be lower than tax due (i.e. 26%) for the capital gain that would have generated without the application of the allowance.