Italy Tax Agency Clarifies Tax Credit Offset Rules for Taxpayers Under Two-Year Arrangement With Creditors

The Italian Revenue Agency Feb. 11 issued Letter No. 36/2026, clarifying tax credit offset rules for taxpayers under a two-year arrangement with creditors (CPB). The taxpayer, a company, joined the CPB for 2024-2025 and achieved the tax reliability score (ISA) required for bonuses. The taxpayer inquired whether it could use a direct tax credit from 2023 for offset if it didn’t have a compliance visa due to lack of a conformity stamp on its 2023 tax return. Upon review, the Tax Agency clarified that: 1) the CPB enhances bonuses only for the agreed 2024-2025 periods; 2) for credits accrued before ...