In accordance with recent rulings of the Supreme Court, the Tax Agency adjusts the rate of the registration tax to be paid for the related deeds constituting the right of surface on agricultural land.
This is what the Tax Agency Agency stated with resolution no. 23/E of 3 April 2025, in contrast to the previous practice orientation. The Agency reached these conclusions by aligning itself with the orientation of the Supreme Court, most recently expressed with order no. 27293 of 22 October 2024, in which the applicability of the registration tax with the rate of 9% was affirmed to a deed constituting the right of surface on agricultural land for the construction of a photovoltaic plant.
Studio Ariotto is available to evaluate and prepare requests for reimbursement and appeals to the Tax Agency.