Italy Tax Agency Clarifies Main Activity Under Two-Year Arrangement With Creditors

The Italian Revenue Agency Feb. 12 issued Letter No. 39/2026, clarifying the main activity for applying the tax reliability score (ISA), for the two-year arrangement with creditors (CPB). The taxpayer, a construction company, reported no sales revenue in 2024 due to projects still being in the construction phase, but recorded increases in inventories of properties intended for resale. The taxpayer sought clarification on whether if, for ISA purposes, it could use the main activity code of construction and opt into the CPB for 2025-2026 without sales revenue. Upon review, the Tax Agency clarified that: 1) for the activity code, revenues ...