Italy Tax Agency Clarifies Applicability of Redemption Regime to Revaluation Reserves

The Italian Revenue Agency Feb. 10 issued Letter No. 27/2026, clarifying application of the redemption regime under Legislative Decree No. 192/2024 to revaluation reserves. The taxpayer, a company, incurred revaluation reserves in tax suspension. The taxpayer inquired in part as to the possibility of exercising the redemption option by a late declaration. The Tax Agency clarified that: 1) failure to complete the statement of capital and reserves in previous tax periods, and its tax-suspended reserves section, didn’t preclude full or partial redemption; 2) the taxpayer’s exercise of the redemption would have the effect of removing the tax suspension constraint on ...