(Adnkronos) - “Ci troviamo di fronte ad una riforma di grande utilità ma forse si poteva fare qualcosa in più. Speriamo che, magari riorganizzando meglio le risorse a disposizione in sede di correttivo, si possa porre rimedio a qualche piccola inefficienza”. Lo ha detto Alberto Trabucchi, co-managing director and head of Tax department di Assonime, intervenuto all’evento “EY Tax Update 2025. Riforma fiscale: sfide e opportunità per le imprese”, organizzato da EY e focalizzato, appunto, sulla riforma fiscale in corso.
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00:00With the reform, the re-alignment regimes have been completely reorganized.
00:09Today there is a unique discipline, certainly easier to manage.
00:13There is the possibility of re-aligning separately between IRES and IRAP.
00:18The system is certainly more coordinated because the deadlines, which were previously unaligned,
00:24today are re-aligned, shortening those that were probably excessively long,
00:30but above all extending those that were difficult to apply.
00:35Liquids, let's say, have worsened from this point of view.
00:38There is no doubt, but the global re-alignment has been unlocked,
00:41which today is basically always feasible.
00:44The last thing that can perhaps be underlined is that in eliminating the arbitrages
00:50that could have been carried out by exploiting the aliquots, which were actually much more convenient,
00:56the possibility of incentivizing corporate aggregation operations with third parties has also been eliminated,
01:02which could have been carried out by exploiting the low re-alignment aliquots.
01:07It is true that the arbitrages for the infragroup operation have been eliminated,
01:11but there is the risk that a possible form of incentive has also been eliminated
01:16for corporate reorganizations towards third parties, those for growth,
01:20so this could perhaps be a reason for rethinking.
01:23We live in a context where we have the regime of fiscal consolidation,
01:27which is among the most favorable among those existing in the European panorama,
01:35and therefore the regime of fiscal consolidation is always the best formula
01:39to allow the circulation of losses within the group.
01:43It must be said that when this regime cannot be applied,
01:46rather than perhaps for the first years of application or constitution of societies
01:51for which, as I know, it is not possible to activate the consolidated,
01:54the reform for stable groups certainly allows a better management of losses,
02:00because the goodness of the unitarily understood economic subject is recognized substantially at the fiscal level,
02:07allowing the circulation of losses in the hypothesis of subsequent aggregation operations
02:13between the subject who brings the losses, the subject who controlled it, or between subjects of the group.
02:18Let's say that from a substantial point of view,
02:24the choice made by the legislator for a matter of prudence on the jetty
02:28was to allow this exchange of losses only in pairs,
02:34that is, only in the measure in which the subjects that are going to aggregate
02:38were already together, were already part of the same group at the time of maturation of the losses.
02:42This is a fairly strong limitation, which then leads to a series of complications
02:47that will be solved by the IMF, which is in the process of preparation at the IMF,
02:52and which perhaps make it still advisable, when possible, the use of fiscal consolidation.
03:00It would have been another idea to allow a free circulation of losses in the group
03:04with a growing logic, that is, regardless of the moment in which the societies were part of the same group,
03:10but probably for jetty reasons it was not possible to pursue it,
03:15and therefore we are faced with this reform, I repeat, of great utility,
03:19but perhaps something more could still be done,
03:22and we hope that maybe, by better reorganizing the resources available in the correctional headquarters,
03:27we can remedy this, let's say, small inefficiency.