With Circular letter no. 6/E of March 1, 2022 (hereinafter, the “Circular Letter“), the Italian tax authorities issued clarifications regarding the regulations set out in art. 110 of Law Decree no. 104 of August 14, 2020, implemented, with amendments, by Law no. 126 of October 13, 2020 (the “Decreto Agosto”), whereby was (re)introduced:
– a “general” asset revaluation regime aimed at all business entities (including companies, business entities and partnerships, permanent establishments of non-resident entities, etc.) that do not adopt international accounting standards in the preparation of their financial statements;
– the possibility to proceed with a tax step-up (so-called “realignment”) of the higher values already recorded in the financial statements, also for the benefit of “IAS adopter” parties.