The recent Omnibus Decree (Decreto Omnibus) introduced an exception to the access restrictions for the Biennial Preventive Concordato (Concordato Preventivo Biennale – CPB). Previously, professionals carrying out activities both individually and through an association with colleagues were barred if the ISA (Synthetic Reliability Indices) codes differed. The new provision, effective for the 2026 tax period, allows participation in the CPB even when the professional’s individual ISA code differs from that of the associated entity, provided certain conditions are met. This change aims to broaden the uptake of the cooperative compliance tool among professional firms.
Key Takeaways
- Barrier Removed: Differing ISA codes between a professional and their associated firm no longer automatically preclude CPB access.
- Enhanced Participation: The amendment is expected to increase adoption of the biennial concordato among multi-partner professional practices.
- Conditionality Applies: Taxpayers must still satisfy all other CPB eligibility requirements, including regular tax compliance and absence of significant disputes.
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