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European Union and Italian International Tax Law Blog

participation exemption

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No Participation Exemption in the Absence of Active Business

By Marco Rossi on December 11, 2009

Participation exemption rules do not apply to gains from sale of stock of passive intellectual property holding companies. For the exemption to applies, the company must be engaged in an active licensing business, which includes the active management and development of the intangibles and active licensing to third parties.…

Posted in Italian Taxation of Companies and Businesses
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My name is MARCO ROSSI and I am an international lawyer specialized in EU and Italian international tax law for foreign individuals and companies investing or doing business in Italy and the EU. I am based in New York and…

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