The Italian Revenue Agency has published Ruling No. 3 of 10 January 2019 on the application of tax rules limiting the carry forward of losses following a merger, which are meant to limit the offset of carried forward losses where mergers are conducted for the purpose of taking advantage of the losses. The Ruling concerns a case where the surviving company of a reverse corporate merger wanted to claim its losses incurred prior to the merger, while not claiming any loss of the non-surviving co…