Super Ace also for the 2021 revaluation reserves
During the annual meeting between the specialized press and the experts of the Revenue Agency, important clarifications were provided regarding the so-called super ACE (Help to Economic Growth).
With specific reference to the revaluation reserve recognized in the financial statements as at 31 December 2020 pursuant to Legislative Decree n. 104/2020, the Agency confirmed that it contributes to the formation of the ACE base as it becomes free due to the realization of the higher values recorded in the financial statements. This reserve therefore constitutes a significant increase for the purposes of the super ACE pursuant to art. 19, D.L. n. 73/2021, for the “realized” portion (through depreciation or following the sale of the asset) in the year 2021.
The intervention in question is in substantial continuity with the previous interventions of the financial administration. The latter, in fact, had already expressed itself in the response to question n. 889 of 30 December 2021 and with circular letter n. 21/E/2015. In the two documents, the Revenue Agency had argued that the revaluation reserve assumed relevance for ACE purposes when it became available following the implementation operations such as the sale of the revalued asset or its depreciation.
It is important to underline that for the calculation of the Super ACE the amount deducted for tax purposes is not recognized but only the statutory deducted amount counts.