Loan for ship construction and “tonnage tax” regime

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By replying to the inquiry  filed by a shipping company, Italian Tax Office clarified that, if a bank partially waives  the claim arising out of  the loan for the construction of a ship subject to the tonnage tax regime, the relevant windfall gain follows the aforesaid regime and cannot be independently subject to IRES (Italian tax on companies income). In this respect, Italian Tax Office pointed out that, according to  the tonnage tax provisions, revenues  and/or losses arising out of  the sale of a ship, which is subject to the relevant regime, are already included in the taxable income.