Hybrid Financial Instruments under Italian Tax Law: The Case of Participating Financial Instruments

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Authors: Michele Barcellona, Federico Aquilanti, Gabriele Barone
Cited by: 1
References: 4

Abstract

Participating financial instruments (strumenti finanziari partecipativi, PFIs), introduced into Italian corporate law by the 2003 reform, are hybrid instruments combining equity-like and debt-like features. Despite their structural flexibility, the absence of a detailed statutory framework has long limited their use, while enabling innovative applications in restructurings, private equity, venture capital and incentive schemes. This article analyses PFIs under Italian law, focusing on their tax qualification for issuers and investors. Particular attention is paid to interpretative issues raised by the tax authorities, treaty classification of PFI proceeds and conversion mechanisms.

Fields of Study & Subjects

Corporate Governance and Law Global Financial Regulation and Crises Corporate Insolvency and Governance

Publication details

Journal / source
European Taxation
Publisher
IBFD
Volume
66
Issue
2/3
Publication date
16 February 2026
Language
EN