An assessment for IRES, IRAP and VAT purposes, payable by a company, can also be based on the examination of the personal current accounts of the shareholders, especially in the case of small and family-based companies. This is the principle expressed in ordinance no. 35856 of 22 December 2023, by the Court of Cassation. according to the Judges, the small size of the social group is sufficient to justify, unless proven otherwise, the traceability of the operations carried out by the members of the company to the economic activity of the investee company.
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