On 12 February 2026, Italy’s Revenue Agency aligned its VAT rules with EU law, allowing special purpose vehicles in merger‑leveraged buyouts to deduct input VAT on transaction costs. Resolution No. 7/2026 confirms these SPVs as VAT‑taxable entities, following Supreme Court rulings in August 2024 that recognised their preparatory role. The change restores VAT neutrality and opens a refund window for historical VAT leakage.
On 12 February 2026, the agency abandoned its restrictive practice, aligning with the Supreme Court and EU.
It confirms that such SPVs qualify as VAT taxable entities and may deduct input VAT on transaction costs.
Decisions Nos. 22608 and 22649 of August 2024.
By using the refund mechanism under Article 30 ter of Presidential Decree No. 633/1972, supported by robust documentation.
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