The Italian Revenue Agency (IRA) has published Ruling No. 39 of 20 January 2022, which addresses the loss forfeiture rules provided by article 84(3) of the Italian tax code in cases where there is an indirect transfer of ownership in a company. The particular case covered in the ruling essentially involves a taxpayer that had acquired indirect ownership (control) of a company (ALFA) through the acquisition of another company holding a majority of the shares in ALFA.
Prior to the acquisition…