Tax & Legal

In three cases from Italy, the European Court of Justice decided that the freezing of funds and economic resources linked indirectly, through trust structures, to persons subject to restrictive measures taken by the European Union in view of Russia’s military aggression against Ukraine does not contravene EU law.

In a recent judgment, the Supreme Tax Court held that the loss offset restrictions of Section 15b of the Income Tax Act would come into effect if the investor did not actively participate in the project. This also applies if the initiator of a tax deferral model, as a founding partner, participates on the same terms as the other investors.

The Supreme Tax Court has referred to the ECJ on a refusal to grant the same inheritance tax allowance on a holding in Canada that would have been available on a domestic investment.