Italy

On 23 October 2026, the Italian Revenue Agency issued Resolution no. 38/2026, establishing 20 new tax codes (codici tributo) for the payment of the single penalty (sanzione unica) applicable in cases of legal cumulation (cumulo giuridico) during voluntary disclosure (ravvedimento operoso). The legal cumulation mechanism, introduced by Article 3 of Legislative Decree no. 87/2024, applies

On 22 October 2026, the Italian Supreme Court (Corte di Cassazione) issued ordinance no. 26382/2026, ruling that provisions for environmental recovery costs associated with the future decommissioning of an incineration plant are not deductible for corporate income tax (IRES) purposes. The plant operated under an integrated environmental authorization (AIA) issued by the Region. The Court

The Biennial Preventive Concordat (CPB) 2026-2027 introduces a critical limitation: the differential income eligible for the favorable substitute tax rates (10%, 12%, or 15% depending on reliability score) is capped at €85,000. Any positive differential exceeding this threshold is taxed at ordinary rates—43% for IRPEF taxpayers and 24% for IRES subjects. This cap significantly reduces

The Ministry of Economy and Finance (MEF) has opened a public consultation on 22 October 2026 regarding the potential revision of the €85,000 revenue threshold for the flat-rate regime (regime forfettario). The consultation seeks input from professional associations, businesses, and academics on whether the current cap—unchanged since 2023—should be increased to account for inflation and

The Italian Supreme Court (Cassazione) has reinforced the evidentiary standards for analytical-inductive assessments (accertamento analitico-induttivo) targeting bars and public establishments. In a ruling dated 20 October 2026, the Court held that revenue reconstruction cannot rely solely on applying average markup percentages (ricarico medio) across heterogeneous product categories. Instead, the tax office must account for product-specific

The Rottamazione-quinquies for local authorities (enti territoriali) allows taxpayers to settle tax and non-tax debts entrusted to the Collection Agent (AdER) between 2000 and 2023 by municipalities that have adhered to the measure. Applications must be submitted online by 15 December 2026. The scheme waives penalties and interest, requiring payment of only the principal amount

Legislative Decree No. 219/2023, as amended, has made the preventive contraddittorio (pre-assessment adversarial proceeding) mandatory for most tax assessments. The administration must communicate the draft assessment act (schema di atto) and grant the taxpayer at least 60 days to submit observations, request a hearing, and access the investigation file. The measure, effective from 2024, applies

On 21 October 2026, the Italian Revenue Agency released the definitive version of Part II of the circular interpreting the tax provisions of the Business Crisis and Insolvency Code (Codice della Crisi d’Impresa e dell’Insolvenza – CCII), Legislative Decree 14/2019 as amended. This circular follows the public consultation on the draft published in June 2026

On 21 October 2026, the CNDCEC hosted a free live webinar for registered chartered accountants presenting the Unified VAT Text (Testo Unico IVA) within the broader 2027 tax reform. Keynote speakers included Vice Minister of Economy and Finance Maurizio Leo and Revenue Agency Director Vincenzo Carbone. The session outlined structural changes: a single VAT code

On 21 October 2026, the Italian Tax Authority (Agenzia delle Entrate) published updated guidance on the Global Information Return (GIR) under the OECD Pillar Two Global Minimum Tax framework. The revisions aim to simplify reporting obligations for multinational enterprise (MNE) groups while enhancing data quality and consistency across jurisdictions. The changes align with the OECD’s