The tax authorities clarified that a single EU holding company can indirectly include Italian entities in two separate VAT Groups when expanding in Italy through acquisitions and establishing a permanent presence.
Italy’s tax authorities clarified that a single EU holding company can indirectly own Italian entities that belong to two separate VAT Groups.
This is permissible when expanding its presence in Italy through acquisitions and the creation of a permanent establishment.
The clarification was released in Ruling No. 211/2025.
