Studio PonchioSTPTax Observatory · – 17 July 2026
Contributing shareholdings to equity: when the controlled realisation regime of art. 177 applies
Contributions and exchanges of shareholdings — art. 177 of the Italian income tax code, controlled realisation regime
The controlled realisation regime allows, on certain conditions, contributions and exchanges of shareholdings without an immediate taxable capital gain: the tax basis carries over to the shareholding received.
It is a central tool in family reorganisations and holding structures: the requirements (controlling or qualified percentages, increase in equity, consistency of values) must be checked rigorously before the transaction, to avoid recharacterisation.
Summary note by Studio Ponchio, based on specialised tax sources. The text does not reproduce the original contributions and does not constitute professional advice.
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