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Clifford Chance

Clifford Chance

Briefings

Conversion of DTAs into tax credits through disposal of non-performing receivables: Q&A

16 April 2020

The measures to support businesses during the Covid-19 epidemic include, under the specially enacted "Cura Italia" Decree, the option of transferring non-performing receivables and to obtain the right to convert into tax credits deferred tax assets (DTAs) deriving from tax losses and excess notional interest deduction (NID). The conversion into tax credits is allowed for an amount of DTAs not exceeding 20% of the face value of the transferred receivables, up to a maximum of Euro 2 billion of transferred receivables.

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