01
Document overview
Current Tax Group formation and change rules covering ownership, residence, pre-group losses, intra-group transfers, entry, exit and notifications.
- Applies from 2025 periods.
- MD 125/2023 is replaced prospectively.
- Certain notifications: 20 business days.
02
Scope and exclusions
Applies to
Applies to tax groups for periods beginning on or after 1 January 2025; includes a 20-business-day notification rule for specified changes.
Limitations and exclusions
MD 125/2023 remains historically relevant to earlier periods but must not be shown as the current regime after 1 January 2025.
05
Official primary source
Ministerial Decision No. 301 of 2024
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