Transfer of VAT Credit in Corporate Reorganization Involving Three Parties, One Unregistered in Italy

• ALFA is an Italian company established by Gamma Ltd to acquire and continue the business of BETA.
• ALFA acquired a business unit from BETA through a complex reorganization involving Gamma Ltd, a UK entity not registered for VAT in Italy.
• The business unit was partially transferred to ALFA by Gamma Ltd.
• ALFA continued the business activities and assumed legal relationships related to the business units.
• ALFA seeks to use the VAT credit accumulated by BETA in 2024 to purchase or import goods and services without paying VAT.
• ALFA inquires if the formal communication of the VAT credit transfer can be submitted late with penalties and seeks guidance on completing the communication form due to the dual transfer process.
• ALFA believes financial administration guidelines on VAT credit transfers in extraordinary operations apply, despite involving three entities, including one not registered for VAT in Italy.

Source: agenziaentrate.gov.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.