The Tax Supreme Court defines the so-called ” leading holding companies”


In a decision dated 13 June 2018, the Supreme Court provides very welcomed comments about the discussed concept of “leading holding company”.

A method based on items of evidence is chosen, the Court giving greater importance to objective criteria and facts in order to characterize the managing and leading role of a given holding company.

One of the most important points about this decision is that the Court allows a company to be considered as a leading holding even if it does not provide services/management to some of its minority subsidiaries.


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