Exor, the holding company of the Agnelli family that controls 14% of the Stellantis group, Has reached an agreement with the Revenue Agency to close a tax dispute relating to re-settlement in the Netherlands in 2016. Exor, headquartered in the Netherlands, will pay 746 million euros, 104 million of them in interest Giovanni Agnelli, The company that controls Exor, today set its suspension with the tax authorities for 2016: it will pay to the Revenue Agency 203 million, of which 28 million is for interest. all the time 949 million euros.
Six years ago Exor decided to move its tax residence to the Netherlands because Dutch was already the residence of many of its subsidiaries, such as Cnh Industrial, Fiat-FCA and Ferrari (Stellantis has also chosen the Netherlands to set up its headquarters in 2021. The transfer was achieved by merging with Dutch subsidiary Exor Holding NV and thus applying the Participation Exemption Regulation (PEX).
Thanks to this scheme, 95% of any capital gains Therefore, it was excluded from the taxable income of the holding company To determine the exit tax. However, with a subsequent ruling, the Revenue Agency argued that the exemption should not apply to cases where a holding company moves its tax domicile abroad. without maintaining a permanent establishment in Italy, as in Exor. Exit tax isone time tax On capital gains Made on the occasion of the transfer of residence to another country belonging to the European Union.
Transport, Exor wrote, was motivated by “the need to Harmonization of governance systems and corporate law rulesOr, it is not financially convenient: the tax treatment on capital gains is practically the same in Italy and the Netherlands.” This news comes as the Italian government prepares to launch a loan of 400 million euros to build the new Stellantis factory for electric batteries in Termoli.
In fact, things are a bit more complicated Given that beyond the rates there Different criteria for determining the tax base The country is seen as a kind of “hub” for transferring funds to more favorable tax authorities. According to calculations, every year the Netherlands subtracts tax revenue from Italy for about 1.1 billion euros. To avoid a long and costly tax dispute, the memorandum continues, Exor has chosen to sign the agreement and pay the agreed amount, While she remained completely convinced that she acted correctly Claim not to violate any rules related to the subject exit tax. To confirm this interpretation – Exor points out – there is the fact that the Revenue Agency has not imposed any penalty in connection with the dispute raised: the amount paid by the two companies for exit tax corresponds only to a recalculation of the higher taxable amount. and related interests.
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