The Growth Decree 2019 added to art. 177 Tuir paragraph 2-bis, extending the regime of controlled profits also to the cases of contributions of so-called “qualified” shareholdings, made in existing or newly established companies, in which the transferor holds the entire capital.

Qualified shareholdings are those which have voting rights at ordinary shareholders’ meetings of more than 2 or 20% or shareholdings in capital or assets of more than 5 or 25%, respectively for securities traded on regulated markets and other shareholdings.

This new discipline seems to be aimed at favoring the creation of those individual holding companies containing the investment portfolio of the sole contributing shareholder, thus facilitating portfolio management also from the point of view of tax collection.

On the basis of its experience and competence in the specific legal and commercial fields, Studio Tributario Societario Internazionale is available with its professionals for consulting and support activities, as well as for any further study and evaluation.