Italy Tax Agency Clarifies Tax Treatment of Capital Gains From Sales of Bank Shares

The Italian Revenue Agency Feb. 11 issued Letter No. 33/2026, clarifying the application of corporate income tax (IRES) and regional tax on productive activities (IRAP) to capital gains from sales of bank shares, under Legislative Decree No. 153/1999. The taxpayer, a company formed from a bank reorganization, sought clarification on whether the gain from sales of bank shares from the reorganization qualified for exemption from IRES and IRAP under the decree. The Tax Agency clarified that: 1) the exemption relief didn’t apply because the taxpayer wasn’t a smaller banking foundation under the decree, and its sales were carried out after ...