The Revenue Agency clarified that if a company receives a DTA tax credit from another company, it can only cash it in, not use it to pay other taxes.
Italy’s Revenue Agency clarified on 4 December 2025 that companies acquiring tax credits arising from the conversion of Deferred Tax Assets (DTA) cannot use these credits to offset or transfer them further and can only monetise them through refunds.
This guidance comes in response to no. 300 of 4 December 2025, addressing a ruling request from a company that purchased DTA-related tax credits under Article 2 of Legislative Decree no. 225/2010.
The company asked whether it could report the credits for offsetting in its tax return, referencing prior clarifications provided for similar credits under Article 44-bis of Legislative Decree no. 34/2019.
The Revenue Agency confirmed that, under Article 43-bis of Presidential Decree no. 602/1973, credits requested as refunds cannot be further transferred or used for offsetting. Previous rulings (nos. 253/2025 and 259/2025) support this approach, emphasising that the assignee’s only option is to collect the credit as a refunded amount.
In conclusion, while the credit can be acquired and monetised, any attempt to offset it against other tax liabilities or transfer it further is prohibited.
