The Italian Supreme Court confirms that, pursuant to Article 88(4-ter) of the TUIR, debt discharge gains do not contribute to taxable income where fully offset by tax losses, including carryforwards, within the framework of restructuring agreements under Article 182-bis of the Italian Bankruptcy Law. The ruling reinforces the principle of tax neutrality in restructuring transactions.
Published in In La Circolare Tributaria no. 17/2026 Euroconference.
