The holding Exor of the Elkann family has multiple interests in the automotive field, thanks to Stellantis, Ferrari and Cnh Industrial. A long time has passed since the time of Avvocato Agnelli, but the heirs continue to deal with cars. And despite the headquarters in the Netherlands, they continue to have a certain ‘relationship’ with the Italian tax authorities. In fact, on February 18, Exor announced that it had reached an agreement with the Revenue Agency: will pay 746 million euros to close a tax dispute relating to the re-domiciliation in the Netherlands in 2016.
“Giovanni Agnelli Bv, parent company of Exor, has also settled its pending debts with the tax authorities for 2016 regarding the determination of the Exit Tax by the old limited partnership of the outgoing family, Giovanni Agnelli e CSapaz .: it will pay 203 million to the tax authorities , of which 28 million for interest“, Reports the Corriere della Sera. In all, the bill will reach almost one billion euros.
“The issue is linked to the Italian company Exor SpA which in December 2016 merged with its Dutch subsidiary Exor Holding NV to create today’s Exor. On the occasion of such a cross-border merger, the outgoing company Exor SpA applied the Participation Exemption (PEX) discipline referred to in Article 87 of the Corporate Income Tax Act. Under this regime, 95% of any capital gains relating to the value of its shareholdings were exempt and therefore excluded from the taxable income of the holding company for the determination of the Exit Tax. Subsequently, the Revenue Agency considered that the PEX should not apply to cases in which a holding company transfers its tax domicile abroad without maintaining a permanent establishment in Italy.“, Communicated Exor.
“Following the subsequent principle of law published in 2021, a complex interpretative question arose on the application of the PEX legislation as early as 2016. Exor remains convinced that he acted according to the rules. However, with the aim of avoiding the time and costs of an important tax dispute, the Company has decided to enter into a settlement agreement with the Revenue Agency. Exor underlines that with respect to the claim relating to the PEX, the Revenue Agency has not imposed sanctions. There are no tax pending pending for Exor for all the years in which the Company was fiscally resident in Italyas the ordinary legal deadlines for any assessment have also expired“, Continues the note.
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