The Italian Revenue Agency issued Resolution No. 7/2026 on 12 February 2026, clarifying that SPVs can deduct input VAT on transaction costs in merger leveraged buyouts only if the taxpayer qualifies as a taxable person and the goods/services are used for taxable economic activities. Holding companies that merely own shares without management participation cannot deduct input VAT. The resolution also addresses the deductibility for holding companies acting as SPVs.
The taxpayer must qualify as a taxable person and the goods and services purchased must be used for taxable economic activities.
No, holding companies that merely own shares without participating in management cannot deduct input VAT because they do not qualify as taxable persons for VAT.
The resolution was issued on 12 February 2026.
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