- In the case of a merger by incorporation, the VAT credit accrued by the incorporated company in the previous calendar year cannot be included in the group VAT.
- The credit can only be used for horizontal offsetting by the incorporating company or requested as a refund when the conditions are met.
- The Italian Revenue Agency clarified this in response to inquiry number 445 on October 9, 2023.
- Similarly, the VAT credit accrued by the incorporated company during the year of the merger by incorporation cannot be included in the group VAT.
Source: ipsoa.it
Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.