As of 21 September 2026, the Italian Revenue Agency (Agenzia delle Entrate) continues its extensive verification campaign targeting COVID-19 emergency state aid distributed between 2020 and 2022. The PwC Tax Incentives & Grants Team warns that the control dossier remains open, with the tax authority actively auditing compliance with eligibility requirements, calculation accuracy, and the “single enterprise” (impresa unica) ceiling for de minimis and Temporary Framework aid. The article highlights that many businesses have yet to finalize their self-assessment declarations, and the statute of limitations for recovery actions extends well beyond the initial disbursement period. Key focus areas include the correct determination of the reference group for the single enterprise test, proper allocation of aid intensities across different schemes, and documentation supporting the pandemic-related revenue decline. Companies that received any form of COVID support—ranging from non-repayable grants (contributi a fondo perduto) to tax credits for rent, sanitation, and advertising—must ensure their files are audit-ready, as the Agency is issuing formal questionnaires and requesting underlying accounting records.
Key Takeaways
- Extended Verification Window: The Revenue Agency retains broad powers to recover improperly granted COVID aid, with prescription periods running up to ten years from the date of the final award decision.
- Single Enterprise Test Complexity: Groups with cross-border structures or multiple Italian entities face heightened scrutiny on the aggregation of aid ceilings, requiring consolidated mapping of all received support.
- Proactive Remediation Advised: Taxpayers should conduct internal audits of past aid applications, reconcile amounts with tax returns, and prepare voluntary disclosures where discrepancies are identified to mitigate penalties.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement