The Italian Revenue Agency has published Resolution No.38/E of 29 March 2019 concerning the application of financial transaction tax on the sales of shares between companies with common control. The resolution addresses a case involving the sale of an Italian entity by a Dutch holding company to a UK holding company, both of which are owned by two other Dutch and UK entities in the same proportion (50% each). The sale is part of a reorganization for simplification purposes. The resolution pr…