PROFILI FISCALI DELLE PARTECIPAZIONI AUTO-ESTINGUIBILI

The self-extinguishable shareholding scheme is functional for several needs, strengthening the company’s assets and generational transition, as shaped by statutory autonomy. As an instrument of free transfer of wealth to other shareholders, they must be carefully evaluated for inheritance and gift tax purposes. The moment the instrument is adopted, there is tax neutrality. It is only with the extinction and thus with the accretion that indirect enrichment of the other partners can, eventually, be realized, however, conditioned on the verification of assumptions of a formal nature, which are not easily identifiable.