Published on 3 October 2026, Legislative Decree 147/2026 implements a comprehensive reform of administrative penalties for regional and local taxes (IMU, TARI, regional surtax on IRPEF, etc.). The decree aligns the sanctioning regime for these taxes with the general principles of the Tax Penalty Statute (Legislative Decree 472/1997), ensuring consistency, proportionality, and taxpayer rights. A major innovation is the expanded applicability of the voluntary disclosure mechanism (ravvedimento operoso) to all regional and local tax violations, allowing taxpayers to regularize omissions or errors with reduced penalties before any audit activity begins. For violations committed from 1 January 2027, the decree introduces predetermined penalty amounts for specific infractions (e.g., late payment of IMU, omitted TARI declaration), replacing the previous discretionary ranges.
Key Takeaways
- Harmonization with General Penalty Framework: Regional and local tax penalties now follow the same tiers (formal, material, criminal) as state taxes. The base penalty for late payment is 30% of the unpaid tax (reduced to 15% if paid within 90 days), and for omitted declarations, it ranges from 120% to 240% of the omitted tax. The decree eliminates previous discrepancies where some regions applied higher or lower rates.
- Voluntary Disclosure Extended to All Local Taxes: Taxpayers can now use ravvedimento operoso for any regional or local tax violation, including those previously excluded (e.g., certain IMU omission penalties). The reduction scales are: 1/10 of the minimum penalty if regularized within 90 days, 1/9 within a year, 1/8 within two years, etc. This provides a powerful tool for compliance, especially for businesses with multi-location properties.
- Predetermined Penalties from 2027: Starting 1 January 2027, fixed penalty amounts will apply for common violations: €250 for late IMU payment per property, €500 for omitted TARI declaration, etc. This certainty reduces litigation but requires municipalities to update their regulation and notification systems. Tax advisors should verify local bylaws for conformity.
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