Management packages: withdrawals of shares from a PEA, taxation in the donor's name and deferral on contribution

Article 24 of the 2026 budget act adjusts the tax regime for management package gains created by the 2025 budget act (Article 163 bis H of the General Tax Code). The shares concerned can be withdrawn from a PEA within five years without closing the plan, realising the gain closing the plan; the gain is calculated from the value of the shares at acquisition and the limit taxed as a capital gain (three times the company's performance) is reduced by dividends and capital repayments received. In the event of a gift, the gain is taxed in the donor's name. The portion taxed as salary benefits from a tax deferral when the gain is reinvested in a contribution or exchange of shares.