- The Palermo Court ruled on January 13, 2026, that VAT adjustment notes are applicable even in simplified liquidation agreements, despite the silence of art. 26 of DPR 633/72.
- This is the first judicial decision to extend such VAT rules to simplified liquidation, based on art. 8 of Legislative Decree 186/2025.
- The favorable tax regime for income taxes on debt reductions now also applies to new procedures under the Crisis Code (CCII).
- Although art. 26 of DPR 633/72 does not explicitly include new CCII procedures, the court found interpretative grounds to apply it to simplified liquidation, making the process tax-neutral for both income tax and VAT.
- Similar conclusions could have been reached interpretatively, highlighting the disparity between unchanged VAT rules and the broader application of income tax relief under Legislative Decree 186/2025.
Source: eutekne.info
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.
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