Where as a result of the sale of the business unit, the assignor can be considered “extinguished”, having ceased any activity relevant for VAT purposes in Italy and consequently closed his VAT position, if the transferee / client has correctly paid the VAT unduly deducted, the successor in title is the person entitled to submit the refund request, starting from the date of reimbursement of the VAT applied at the time by way of recourse to the customer. This was clarified by the Revenue Agency with its response to ruling no. 432 of 24 August 2022.
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