On
June
22,
2020,
the
Company
filed
for
a
VAT
refund
in
the
amount
of
Euro
488,147
by
way
of
the
2020
tax
return
(for
2019
income).
The
reason
given
was
the
lower
excess
credit
not
transferable
for
the
payment
of
group
VAT
(as
per
Articles
33
and
73
of
Italian
Presidential
Decree
633/1972).
On
June
17,
2022,
the
Tax
Office,
after
lengthy
investigative
and
documentary
verification
activities,
notified
the
Company
of
the
recognition
of
the
2019
annual
VAT
credit
requested
for
reimbursement
in
the
amount
of
Euro
488
thousand,
and
also
in
June
settled
the
entire
amount,
including
interest,
as required by law.
6)
Initiation of audit for direct taxes on 2016, 2017, 2018 and 2019 tax years
On
May
11,
2022,
the
Trento
Tax
Agency
notified
the
Company
of
four
notices
of
the
initiation
of
an
audit
on
the
2016,
2017,
2018
and
2019
tax
years,
with
reference
to
the
transfer
prices
charged
by
Aquafil
to
overseas
subsidiaries
for
IT
services,
in
addition
to
the
interest
rates
applied
on
loan
agreements.
On
June
7,
2022,
the
Company
delivered
to
the
Tax
Office
all
the
required
documentation
under
the
citations.
On
August
26,
2022
and
August
30,
2022,
the
Trento
Office
notified
the
Company
of
two
citations
(IRES
and
IRAP)
issued
pursuant
to
Article
5-
ter
of
Legislative
Decree
No.
218/1997
for
the
establishment
of
a
ruling
with
reference
to
the
2016
tax
period,
which
includes
a
potential
tax
recovery
of a total of Euro 1,287 thousand.
On
September
15,
2022,
the
case
involving
both
invited
parties
began,
in
which
the
many
aspects
that
were
not
agreeable,
both
in
the
“an
et
quantum”
(“if
and
how
much”)
were
highlighted,
agreeing
to the drafting of a brief filed on October 3, 2022.
On
November
22,
2022,
while
reaffirming
the
legitimacy
of
its
conduct,
and
solely
in
order
to
avoid
long
and
exhausting
litigation,
the
Company
reached
an
agreed
settlement,
after
submission
of
the
IPEC
Application
by
the
consolidating
company
Aquafin
Holding,
paying
the
amount
of
Euro
16
thousand (IRAP and interest) and Euro 279 thousand (IRES).
To
date,
with
respect
to
the
2017,
2018
and
2019
tax
periods,
no
findings
of
the
Tax
Office
have
been
moved
in
relation
to
these
audits.
At
present,
therefore,
any
quantification
of
contingent
liabilities
is
considered
premature,
as
it
is
necessary
to
await
the
development
of
the
Tax
Office's
investigative
activities for the proper estimation of the findings
.