Corporate StructuringCross-Border BusinessDawgen Global Tax InsightsTax Administration & PolicyTax AdvisoryTax AuditTax ControversyTax Dispute ResolutionTax DisputesTax Risk ManagementTax StrategyTax TechnologyTax Technology & DataTax Treaties
Substance Beats Formality: What the Milan Tax Court’s Luxembourg Holding Ruling Means for Cross-Border Tax Planning
June 3, 2026by Dr Dawkins Brown
Executive Summary International tax planning is entering a new era in which paper structures are no longer sufficient, but genuine commercial substance remains powerful. A recent ruling by the First Instance Tax Court of Milan provides an important reminder that foreign holding companies should not automatically be disregarded simply because they are lean, investment-focused...
