Italy’s Revenue Agency published guidance in Letter No. 104/2026 setting out how income tax exemptions should be applied to pension fund investments in venture capital funds. The document responds to queries from a supplementary pension fund seeking direction on the scope and calculation of tax-free qualified investments.
Central to the guidance is the agency’s clarification that the minimum venture capital fund investment requirement applies solely to new qualified investments. The Revenue Agency explained that the measure used to assess whether a pension fund meets the threshold is calculated with reference to the previous year’s qualifying investment basket. In other words, the minimum-investment test is backward-looking in its calculation base, while its application is forward-looking and limited to newly made qualified investments.
The agency also emphasized that the minimum investment threshold for tax-exempt treatment relates exclusively to income generated by new investments. Income deriving from existing qualified holdings is therefore not captured by that minimum threshold as described in the letter.
Long-term individual savings plans, commonly referred to as PIRs, were explicitly excluded from the venture capital fund calculations under the guidance. The letter makes clear that PIRs do not contribute to the qualifying investment basket used to calculate compliance with the minimum investment requirement.
In addition, the Revenue Agency reiterated that binding commitments and investments deemed eligible that were undertaken after 2017 still qualify for tax-free treatment, provided they meet the particular conditions set out in the applicable rules. The guidance frames those post-2017 commitments and eligible investments as remaining within the scope of tax-exempt treatment when the specified conditions are met.
The advisory note arrives as pension funds have been seeking explicit direction on both tax treatment of venture capital allocations and the relevant holding period requirements. The letter addresses that demand for clarification by detailing how the minimum thresholds are to be applied and which instruments should be counted in the qualifying investment basket.
The Revenue Agency’s response in Letter No. 104/2026 therefore provides a procedural explanation intended to assist pension funds in determining the tax status of income from venture capital fund investments under the existing framework.