07:11 Mar 28, 2011 

This is a section of the text immediately before the term at issue. The text was already translated into English, so I do not have the Italian original.
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Substitute tax 1 - Released of excess of deducted depreciations on tangible assets ex Finance Act 2008 (L. 244/2007, art. 1 (48))

As of the Fiscal Year subsequent to December, 31 2007, it will no longer be possible to apply deductions on an off-balance-sheet basis (Section EC of the Income Tax Return – Form Unico) the costs not charged to Profit and Loss Account

The excess deducted pursuant to Art. 109 (4)(b) of TUIR on fiscal years up to 2007 may be released by paying a substitute tax at the rate of 12 to18 per cent

In case of partial release, it shall apply to consistent classes of off-balance-sheet deductions