the corporate structure acquires management availability. The deed cannot be reclassified for registration tax purposes pursuant to art. 20 of Presidential Decree no. 131/1986, a regulation that does not have a specific anti-avoidance function (especially in the interpretation given by the Constitutional Court, in sentence no. 158/2020).
On the basis of these premises, it concluded that, for the purposes of registration tax, not every totalitarian transfer of shares in companies owning a company represents a transfer of a company as such, subject to the corresponding registration tax.