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Group VAT liquidation – prohibition of attributing previous VAT credit in pending disputes resolution.

  • The company [ALFA] is seeking clarification on the recovery of a previously unclaimed VAT credit during a tax dispute resolution process.
  • The company had a VAT credit from 2004 that was not included in a group VAT procedure in 2005, leading to a tax dispute.
  • After a lengthy legal battle, a court ruled that the company should have included the VAT credit in the group declaration, making horizontal offsets invalid.
  • The company participated in a tax dispute resolution process introduced by a law in 2022, fully paying the VAT owed and seeking clarification on how to recover the VAT credit in the 2024 annual declaration.

Source: agenziaentrate.gov.it

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.

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