The introduction of the Code of Crisis by Legislative Decree No. 14/2019 requires, with reference to the previous Bankruptcy Law, a review of the solutions provided by the Revenue Agency, with the relative critical issues and problems that remain unresolved, with respect to contingent liabilities from debt ‘write-off’ or ‘conversion’. With reference to the accounting and tax aspects of the matter, it is necessary to address in particular the issue of the presence of taxable income in the debt discharge exercise and the consequences arising from possible errors in its recognition.

Contribution by Dr. Giampaolo Provaggi, Founding Partner of GPD, published in Corriere Tributario, October 2022.