italy

Italy Treats Serbia’s Ten-Year Tax Holiday as a Privileged Regime for PEX Purposes

Italy’s Revenue Agency has determined that Serbia’s ten-year corporate income tax exemption for qualifying large investment projects constitutes a privileged tax regime under Italy’s participation-exemption rules, potentially increasing the tax burden on Italian investors exiting Serbian companies that use the incentive. The decision was issued in Ruling No. 135/2026 and concerns the Italian tax treatment of capital gains generated when an Italian investor sells shares in a Serbian company benefiting from the Serbian tax holiday. Under Serbia’s current investment regime,…