by Fabio ChiarenzaHead of Tax Department, Gianni & Origoni
With the answer to Question n. 208 of 8 February 2023 ("Response 208"), the Italian Tax Authority clarified some doubts arisen last year on the tax treatment applicable to the merger of three Italian real estate alternative investment funds (AIFs) managed by the same management company and with a similar investment, upon request presented by a company incorporated under Luxembourg law which invests indirectly in the aforementioned AIFs.
Reply 208. . .