The Italian Revenue Agency has published Ruling No. 74 of 19 November 2018 on the treatment of losses resulting from the application of Italy's patent box regime, which provides for a 50% exemption of qualifying income from qualifying IP. The ruling concerns a company that wants to opt for the regime from 2016 in respect of software income. In calculating the effect of applying the regime, the company determined that the amount of income qualifying for exemption would exceed the statutory pr…