Italy Gazettes Decree on Intra-Group Tax Loss Carryforward Regime

The Italian Official Gazette July 12 published a decree implementing rules on the ability to carryforward tax losses within corporate groups. The decree includes measures: 1) exempting specified intragroup transactions from standard loss carryforward limitations for entities within the same group during the relevant period; 2) prioritizing the use of older losses and clarifying that losses exceeding net equity are not exempt; 3) defining approved losses and establishing how group participation seniority is determined; 4) coordinating these rules with existing tax consolidation provisions; 5) applying transitional rules for certain losses incurred before or after Dec. 31, 2024; and 6) extending ...