Italy has published the Decree of 27 June 2025 from the Ministry of Finance, which regulates the exemption from loss-restriction rules for restructurings within a group introduced by Legislative Decree No. 192/2024, which entered into force on 31 December 2024. The exemption is provided by a new Tax Code article, Article 177-ter, which provides that the general limits and conditions for carrying forward tax losses under Articles 84, 172, and 173 do not apply when the relevant operations (su…