Italy

Italy: TFR3 Model & UNIEMENS: INPS Guidance for Employers, Professionals

Effective 1 July 2026, new rules govern the allocation of TFR (severance pay) for private sector employees hired after 30 June 2026. INPS message No. 3021/2026 introduces the “T3” code in the UNIEMENS flow, allowing employers to indicate the chosen destination. The article provides detailed instructions for compliance. Key Takeaways Automatic Enrollment: New hires are

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Italy: Cross-Border Tax Loopholes Partially Closed by Corrective Decree

The Daily Report of 12 October 2026 highlights a corrective decree addressing cross-border tax avoidance structures. While the decree closes several loopholes used by companies shifting profits abroad, certain fictions remain, particularly regarding substance requirements and transfer pricing adjustments. The analysis covers the interplay with OECD BEPS Pillar Two and domestic anti-abuse rules. Key Takeaways

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Italy: Tax: Hyper-Amortization and CPB Are Cumulable

The conversion of Fiscal Decree 38/2026 into Law 88/2026 modifies Article 16 to explicitly allow the cumulation of hyper-amortization (super-ammortamento) benefits with the Biennial Preventive Agreement (CPB). This means companies adhering to CPB can still claim enhanced depreciation on Industry 4.0 assets. Published 9 October 2026. Key Takeaways Cumulation Confirmed: No longer mutually exclusive; taxpayers

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Italy: Tax Audits: CIN Code Helps Uncover Hidden Economy

The National Identification Code (CIN) for short-term rentals, introduced to combat the shadow economy, is now being used by tax authorities to cross-reference property listings with declared income. As of 9 October 2026, the Revenue Agency can match CIN data with tax returns to identify undeclared rental revenue. Hosts must ensure registration and accurate reporting.

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Italy: Tax Notice to Non-Cohabiting Relative: Validity Rules

The Supreme Court clarified that notification of a tax collection notice to a non-cohabiting family member is valid when delivered at the taxpayer’s residence and the family relationship creates a presumption of subsequent transmission. Cohabitation is not a strict requirement. This interpretation, dated 9 October 2026, balances procedural efficiency with due process. Key Takeaways Presumption

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Italy: Tax Role Extract, Unserved Notices: Supreme Court Latest Rulings

In ordinance No. 11898/2026 dated 9 October 2026, the Supreme Court held that the extract of the tax role (estratto di ruolo) is not independently appealable. However, taxpayers may challenge the underlying role and unserved collection notice if they demonstrate one of the legally recognized prejudices, such as denial of financing due to the extract’s

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Italy: Italy Biennial Concordat Free Webinar October 8 for Accountants

The National Council of Chartered Accountants (CNDCEC) is hosting a free live webinar on 8 October 2026 dedicated to the Biennial Preventive Concordat (CPB). The event, exclusively for registered chartered accountants (commercialisti), will feature high-level interventions from Deputy Minister of Economy and Finance Maurizio Leo and Revenue Agency Director Vincenzo Carbone. The webinar aims to

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Italy: TFR and Complementary Pension: Defining First-Hire Workers

Starting 1 July 2026, private sector employees hired for the first time are automatically enrolled in a complementary pension fund unless they actively choose otherwise within 60 days. The article details how to identify “first-hire” status, considering entire work history, and outlines employer obligations for TFR allocation and UNIEMENS reporting. Key Takeaways First-Hire Definition: Workers

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Italy: Pending Charges Certificate Must Reflect Transfer Date Status

The Daily Report of 9 October 2026 emphasizes that the certificate of pending charges (certificato dei carichi pendenti) must reflect the legal and fiscal situation exactly at the date of business transfer. This is crucial for M&A transactions where successor liability depends on accurate disclosure of pending tax disputes and debts. Key Takeaways Snapshot Requirement:

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Italy: Southern Italy 4.0 Investments: Funds Exhausted in One Day

The call for sustainable Industry 4.0 investments in Southern Italy (Mezzogiorno) saw all allocated funds exhausted within a single day of opening, on 8 October 2026. The overwhelming demand underscores the appetite for digital transformation in the region. Stakeholders urge the government to replenish funds in the next budget cycle. Key Takeaways Instant Oversubscription: Applications

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