Newsalert | Tax 13/02/2026

With Resolution No. 7/E of 12 February 2026, the Italian Revenue Agency addressed the VAT treatment of transaction costs incurred by special purpose vehicles (SPVs) in the context of merger leveraged buy-out transactions carried out pursuant to Article 2501-bis of the Italian Civil Code. 

In the latest newsalert, Chiomenti Professionals analysed the Resolution, which is of particular significance as it incorporates the most recent case law of the Court of Justice of the European Union and the Italian Supreme Court, overcoming the restrictive approach previously adopted in administrative practice with reference to so-called "static" holding companies and clarifying the correct VAT classification of SPVs in MLBO transactions.