Avv. Andrea Santoro

There comes a moment in the life of a company when financial results, while remaining an essential element, are no longer sufficient to tell its full story. Growth is also measured through the choices made, the way relationships with clients and collaborators are built, attention to governance, the ability to innovate, and the commitment to generating a positive and lasting impact.
With the start of the new 2026-2027 two-year period, the Concordato Preventivo Biennale (CPB) is back in the spotlight. This instrument, introduced by the legislator with Legislative Decree No. 13 of February 12, 2024, is part of a broader tax reform process aimed at fostering a more collaborative relationship between taxpayers and the Tax Authorities.
Financial statements, guarantees, credit lines, assets. For years, the familiar refrain describing the relationship between businesses and banks has always revolved around the same elements. Today, however, this framework is no longer enough. The financial system looks at a business in a much broader way. This is a fact. Banks assess the quality of cash flows, business continuity, governance, operational order, fiscal sustainability, and planning capabilities.
The recent regulatory evolution regarding tax collection does not represent a mere technical update of the relations between taxing authorities and the Collection Agent, but marks a profound cultural shift: the transition from static taxation to dynamic taxation, characterized by constant monitoring, continuous information flows, and increasingly integrated controls.
Important news at M.G.C. Finance. The company, 100% owned by Studio Santoro S.r.l., has obtained authorization as a RAO, enabling it to directly support the issuance of CNS, digital signatures, and SPID.
Many businesses build value. Unfortunately, few realize they must protect what makes them recognizable. In this sense, trademark registration is only the first step. When protected, appraised, and correctly valued, a trademark can become a strategic asset for the company, with equity significance and, where applicable, tax benefits.
TFR reform on the horizon. The 2026 Budget Law significantly amends the rules governing severance pay (TFR). This change is set to affect the financial management of a large number of Italian companies. Specifically, the criterion used to determine the obligation to pay accruing TFR into the INPS Treasury Fund is being revised: the "static" system introduced in 2007 will be replaced by a progressively broader and more dynamic model. Although seemingly technical, the reform carries significant financial, balance-sheet, and pension-related implications for many businesses.
MGC Finance S.r.l., a company held by Studio Santoro S.r.l., recently assisted in the structuring and completion of a tax credit transfer operation, ensuring comprehensive oversight of the legal, fiscal, and contractual profiles until the closing.
The starting point is a very concrete awareness, shaped also by the work carried out in recent years. Today, businesses do not need partial answers, but an integrated vision. The regulatory, tax, and economic landscape has become so complex that addressing it in isolated silos is no longer sustainable. 2026 is the year in which this approach becomes even more central and structured, building on already solid foundations.
With a ruling dated January 22, 2026, the Second-instance Tax Justice Court of Lazio (Ruling no. 435/2026) fully rejected the appeal filed by the Italian Revenue Agency, confirming the full legitimacy of the Research & Development tax credit recognized for a leading company in the tourist transport sector, a long-standing client of Studio Santoro & Partners.

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