The Tax Authority’s response in the event of prior losses and current year income. The procedure illustrated by the Agency produces an advantage for the taxpayer.

With a ruling response dated December 23, 2022, the Tax Authority expressed itself for the first time on the complex tax exemption regime for contingent liabilities from debt discharge obtained in the context of a business crisis, in the presence of prior losses and current year income.

Article prepared by Giulio Andreani and Giampaolo Provaggi, Founding Partner of GPD, published by Il Sole 24 Ore – Rules and Taxes.