Italy Tax Agency Clarifies Capital Gains Taxation Regarding Property Sales for Companies Under Controlled Liquidation

The Italian Revenue Agency July 7 issued Answer No. 177/2025, clarifying the taxation of capital gains regarding property sales for companies under controlled liquidation. The taxpayer, a company under controlled liquidation due to over-indebtedness, sought clarification on whether the capital gain from selling a property during the applicable procedure would be taxed under ordinary rules or those applicable to judicial liquidation. The Tax Agency clarified that: 1) Article 183 of the Presidential Decree of the Republic (TUIR), which allows income to be calculated over the entire insolvency period, applies only to judicial liquidation and not to controlled liquidation; 2) the ...