The new guidelines from the Bank of Italy, Consob and Ivass emphasise the need for buyers of tax credits to carefully analyse their business model when selecting the appropriate accounting treatment. An interesting aspect is related to the relevance attributed to the buyer's tax capacity to offset such tax receivable directly against their tax liabilities rather than selling them on the market. If the buyer has tax capacity, it seems easier for them to keep treating the tax receivables as “held to collect” without adopting fair value accounting, as discussed in our alert which you can find in Italian at the following link: Trattamento contabile dei crediti d'imposta per l'edilizia