Italy Tax Agency Clarifies Termination of Two-Year Preventive Settlement Agreements With Creditors

The Italian Revenue Agency April 1 issued Letter No. 98/2026, clarifying termination of two-year preventative settlement agreements (CPBs) with creditors. The taxpayer, an individual engaged in real estate brokerage, collaborated with a construction client concerning buying and selling properties. The client’s worksite was judicially blocked, and the taxpayer entered into a CPB. The taxpayer sought clarification of whether the continued block constituted an extraordinary event allowing the CPB’s termination and income determination based on actual results. Upon review, the Tax Agency clarified that: 1) the block could be an extraordinary event if independent of the taxpayer’s will, and if the ...