On 6 October 2026, the Revenue Agency released the much-anticipated guiding circular (Circolare n. 18/E) on the Biennial Preventive Concordat (CPB) for the 2026-2027 tax period. The circular provides comprehensive instructions on eligibility criteria, the determination of the concordat income proposal, the adhesion process, and the effects on tax assessments. The deadline for submitting the adhesion declaration is 2 November 2026 (extended from 31 October due to weekend). The CPB allows taxpayers to agree in advance with the tax authority on the taxable base for direct taxes (IRES/IRPEF) and IRAP for two years, providing certainty and reducing audit risk. The circular clarifies the treatment of extraordinary components, the interaction with the patent box regime, and the conditions for revocation.
Key Takeaways
- Adhesion Deadline Firm: Taxpayers must file the CPB adhesion electronically by 2 November 2026; late submissions are not accepted, and the option covers both 2026 and 2027 tax periods irrevocably.
- Income Proposal Methodology Detailed: The Agency prescribes a standardized calculation based on historical data, sector studies (ISA), and adjustments for extraordinary items, with a safety margin to reduce dispute likelihood.
- Audit Protection Enhanced: Adherents benefit from a “compliance shield” limiting the Agency’s verification powers to formal checks, unless fraud or gross negligence is suspected, significantly reducing compliance costs.
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