The question

In 2021 a company benefited from the innovative growth tax relief scheme known as "ACE" ("super" version), which decreased its taxable income. The company participates in the Italian national tax consolidation programme, and thus completes section GN of the Italian income tax return. What tax base does the consolidating entity need to consider when determining tax prepayments for 2022? Does it need to consider the change due to the growth tax relief scheme of the subsidiary, or the income gross of this?
A. P. – Benevento

The innovative growth tax relief scheme provisions of Article 19 of Legislative Decree 73/2021 do not establish exceptions from ordinary rules, thus permitting the use of the relief at the group level in tax consolidation. Consequently, the surplus of the normal and super versions of the scheme – in the latter case net of the share transformed into a tax credit – automatically form the single growth tax relief return attributed to tax consolidation up to the group's total income. When calculating prepayments, the consolidating entity will take account of the normal and super versions of the scheme transferred to consolidation.