Italy Tax Agency Clarifies Use of Income Tax Credits From Transformation of Deferred Tax Assets

The Italian Revenue Agency Oct. 2 issued Letter No. 259/2025, clarifying the use of income tax credits arising from the transformation of deferred tax assets. The taxpayer, a company, intended to purchase deferred tax asset income tax credits from third parties and use them to offset excise tax debts. The taxpayer sought clarification on whether it could use the purchased credits to offset the debts without limitation on amount. Upon review, the Tax Agency clarified that: 1) further transfer of the purchased credits would be prohibited; and 2) the taxpayer, therefore, would only be able to monetize the amount of ...