In the context of a Private Equity deal, Italian tax authorities clarified that:
HoldCo qualifies as a VAT person considering that (i) it provides services subject to VAT to Target and (ii) it receives a specific remuneration for these services
HoldCo can also deduct VAT on transaction costs incurred before starting the provision of services to Target
HoldCo can deduct VAT applying the general pro-rata principle since it carries out both services subject to VAT and VAT exempt financial services (i.e., SHL), the latter being not incidental
