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Recent Italian Supreme Court rulings in 2025 have significantly shifted the landscape for cross-border investments by establishing a “look-through” approach to beneficial ownership, directly impacting tax exemptions for Alternative Investment Funds (AIFs) and their SPVs.
These decisions highlight the need for a rigorous analysis of investment structures and require verifying beneficial ownership through three independent tests:
🔹 Substantive business activity – Assessing actual economic activity.
🔹 Dominion – Evaluating the power to dispose of the income.
🔹 Business purpose – Investigating the (non)tax reasons behind the structure.
Navigating these complexities is now essential for strategic structural optimization in Italy.
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