Newsalert | Tax 02/12/2025

With Judgment no. 30657 of November 20, 2025, the Italian Supreme Court provided important clarifications regarding the transparency taxation of real estate investment funds pursuant to Article 32, paragraph 3-bis, of Decree Law 78/2010, specifically concerning the aggregation of interests held by family members for verifying whether the qualified threshold of 5% has been exceeded.
The ruling, which is of systemic significance as it defines the substantive criteria necessary to assess the autonomous attribution of family members' holdings under the current application of paragraph 3-bis, was analyzed by Chiomenti Professionals in the latest newsalert.