Perdita da intangible e minusvalenza da sua cessione nel regime di patent box: spunti controcorrente

The exploiting cycle of an intangible may result in one or more negative income results and may lead to a loss; the intangible exploiting income loss and the loss deriving from its transfer are two different concepts which have in common, in the patent bow regime perspective, the lack of references to be used to rule their tax treatment. The first clarifications of the Revenue Agency try to fill such gap by finding a solution which, albeit animated by good intentions, is devoid of a law ground.