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Exor agrees with the taxman, Kkr threatens Tim, Facebook a liar, Ita snubs Delta

2 years ago babelfish

Exor agrees with the taxman, Kkr threatens Tim, Facebook a liar, Ita snubs Delta

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EXCERPT FROM AN ARTICLE FROM CORRIERE DELLA SERA ON EXOR-ELKANN:

Exor, the holding company of the Agnelli-Elkann family that controls Stellantis, Juventus Fc, Cnh Industrial, Ferrari and the Gedi publishing group, has reached an agreement with the Revenue Agency to close a tax dispute relating to the redomiciliation in the Netherlands in 2016. Italian state 746 million euros. Giovanni Agnelli Bv, parent company of Exor, has also settled its pending debts with the tax authorities for 2016 regarding the determination of the Exit Tax by the old limited partnership of the outgoing family, Giovanni Agnelli and C. Sapaz .: it will pay to the tax authorities 203 million, of which 28 million for interest. In all, therefore, almost a billion. Both agreements do not entail penalties for the two companies by the Inland Revenue.

"To avoid a long and costly tax dispute, Exor has chosen to sign the agreement and pay the amount agreed, while remaining fully convinced that it has acted correctly and claiming that it has not violated any rule on the subject of Exit Tax", reports a company note. Likewise, Giovanni Agnelli Bv "believes that it has acted correctly and has acted for the sole purpose of avoiding the time and costs of a significant tax dispute".

Technically, this is an assessment with adhesion, one of the most consistent in Italy, second after the one with Kering for 1.2 billion in 2019. The dispute concerns the Italian company Exor SpA, which in 2016 merged with the its Dutch subsidiary Exor Holding NV creating the current Exor. On the occasion of the cross-border merger, the outgoing company Exor SpA had applied the «participation exemption» regime (so-called «Pex»). Under this regime, the capital gains on the value of these equity investments had been exempted and therefore excluded from taxable income for the purpose of determining the Exit Tax in the amount of 95% of their amount. In 2021, the Revenue Agency affirmed the inapplicability of the "Pex" in cases in which a holding company transfers its tax residence abroad without maintaining a permanent establishment in Italy. As a result of the Principle of law published in 2021, a complex interpretative question arose regarding the application of the "Pex" legislation on the 2016 transaction. In order to avoid a lengthy tax dispute, Exor decided to settle, but "the agreement does not involve nor can it be interpreted as an acceptance – nor even a sharing, not even partial – of the theses supported a posteriori by the Revenue Agency ", says Exor who reiterates that the amount paid yesterday to the Treasury is not such as to modify the strategies of development of the holding.

This is a machine translation from Italian language of a post published on Start Magazine at the URL https://www.startmag.it/economia/exor-kkr-tim-facebook-ita-delta/ on Sat, 19 Feb 2022 10:00:20 +0000.