La nuova imposta sul reddito delle società : lineamenti generali,

Planned a few months before the coming into effect, the essay propose an analysis of the new companies income tax general features – which will be henceforth indicated with the simple acronym IRES – which is obliged to square with a double subject: first of all, with the more radically innovative system delineated by the proxy law, moreover without that definition of the criterions level that would have been hoped, which entrusts the income tax to the couple IRE-IRES; second of all, with the concretely enforced part of the reform, whose significance, even though really significant, still allows to recognize an essential continuity between the “old” couple (IRPEF – IRPEG) and the current one (IRPEF-IRES).Two fundamental doubts have been raised by the new structure. The first doubt deals with the opportunity to base the reform on European model, community principles and world experiences, which are far from converging on a widely shared opinion. The second doubt concern the difficult detection of a systematic plan which should be able to sustain and combine all the reform elements and to propose them as the result of an extensive development idea of the income tax system. The reform which has been enforced until now is conceived for the corporations, which have monopolize the attention of the legislator. Also the return to an income tax of a real type , instead of a personal one, which was clearly support in the Libro bianco, seems achieved really diffidently and contradictory, in a general contest which seems to detect a plurality of models.[...