Italy Tax Agency Clarifies Prohibition on Offsetting Tax Debts for Member in Business Network

The Italian Revenue Agency Nov. 12 posted online Letter No. 291/2025, clarifying the prohibition on using tax credits for offsetting tax debts of other taxpayers, under Article 17 of Legislative Decree 241/1997. The taxpayer, a company, proposed to create a business network for shared tax management and credit optimization. The taxpayer inquired whether the network participants could use their tax credits to pay the tax dets of other participants. The Tax Agency clarified that under current legislation: 1) tax credits belonging to network participants couldn’t be used as compensation to resolve tax debts of other participants; and 2) tax debt ...