The Italian Revenue Agency has published Ruling No. 58 on whether a taxpayer that changed its R&D activity can change the average expenditure basis used in determining the increase in R&D expenditure that qualifies for the R&D tax credit. The R&D tax credit is equal to 50% of qualifying R&D expenditure that exceeds the average expenditure for the 2012, 2013 and 2014 tax years.
The taxpayer conducted R&D activities on its own behalf and on behalf of a French company …