In Corriere Tributario (No. 2/2024), Giuliano Foglia and Francesco Capogrossi analyze the impacts, for the purposes of exercising the right to deduct VAT, of transactions involving the sale of shareholdings set up by operating holding companies. In particular, given the guidelines of the Italian Tax Authority and case law published so far and the uncertainties that still exist, attention is drawn to the elements to be considered in determining whether, and under what conditions, transactions involving the sale of shareholdings can be excluded from the calculation of the pro-rata, as occasional or incidental to the company’s own activity, pursuant to Art. 19-bis, comma 2, d.p.R. n. 633/1972 633/1972.