In Il Fisco no. 4/2025, an in-depth analysis is provided on the rules concerning the “capital contribution” granted to taxpayers who participated in the R&D tax credit amnesty, introduced by the 2025 Budget Law.
Diego Avolio’s commentary focuses on several significant unresolved interpretative issues, including the potential (ir)taxability of the contribution disbursed to beneficiaries and its relationship with the “voluntary repayment” procedure in cases where the amnesty is not finalized.
The analysis aims to offer valuable insights into understanding the practical implications of these provisions.