PERCHE’ NON CONVINCE LA PRESUNZIONE DI DISTRIBUZIONE DI UTILI “OCCULTI” NELLE SOCIETA’ DI CAPITALI A RISTRETTA BASE PROPRIETARIA.

Research output: Contribution to journalArticlepeer-review

Abstract

[automatically translated] The jurisprudence of the Supreme Court, which provides for the eligibility of the distribution presumption of profits in a narrow base owned company has, over the years, consolidated; but the latest case law regarding - who planned the extension of the effects of finality to the assessment corporate partner, although it is not foreseen the need for notification to the assessment company - led to a worrying expansion of its field extension . It 'must, therefore, ask ourselves what is actually such a presumption is convincing and that is if it is effectively meeting the evidentiary royalties "minimum" that allow you to be considered well founded an inferential path.
Original languageItalian
Pages (from-to)575-608
Number of pages34
JournalRIVISTA DI DIRITTO TRIBUTARIO
Volume5/2014
Publication statusPublished - 2014

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