Disposals made exclusively for the purpose of corporate reorganization are not subject to the tax on financial transactions (the so-called Tobin Tax): this was specified by the Revenue Agency in Resolution no. 38/E of 29 March 2019.
In this context, it is considered that the reorganization operations, while tolerating a change in the legal ownership of the shareholding, do not admit that the sold shareholding “goes beyond” the perimeter of the corporate group. It follows that transactions that do not modify the corporate structure, nor the percentages of shareholdings or the rules relating to governance, are not taxed.
