When profits are retained within a holding company, the issue should not be how long they have remained in the company, but where that wealth is actually located and what function it serves.

In his article in ItaliaOggi, Domenico Ponticelli analyzes the relationship between tax deferral, the holding company’s financial autonomy, and the rules governing abuse of rights, highlighting a central principle: the mere passage of time cannot transform a normal decision to retain earnings into abusive conduct.

The dividing line, therefore, is not measured in years, but in the concrete separation between corporate assets and the shareholder’s personal sphere.