On 1 October 2026, the Italian Revenue Agency made available in the taxpayer’s digital tax drawer (Cassetto Fiscale) the synthetic summary sheet for the Cooperative Compliance regime (CPB – Collaborazione Preventiva e Trasparenza) for the 2026-2027 biennium. This document is crucial for entities renewing their adhesion after the inaugural 2024-2025 period. It outlines the enhanced benefits for compliant taxpayers, including: (a) exemption from VAT and direct tax audits (except for fraud), (b) priority in VAT refunds, (c) reduced penalties (50% reduction) for any inadvertent errors, and (d) access to a dedicated fast-track ruling process. Additionally, the sheet details the calculation of the special voluntary disclosure (ravvedimento speciale) for the 2020-2023 tax years, a one-time opportunity to regularize past non-compliance with significantly reduced penalties (as low as 1/18 of the minimum) and no criminal exposure.
Key Takeaways
- Renewal Benefits and Enhanced Certainty: Renewing CPB adhesion for 2026-2027 locks in the cooperative relationship, providing audit immunity for standard risk areas. The summary sheet quantifies the expected tax savings from reduced penalty exposure and accelerated refunds. Entities must confirm renewal by 31 October 2026 to avoid lapse.
- Special Voluntary Disclosure for 2020-2023: The ravvedimento speciale allows correction of errors/omissions for tax periods 2020-2023 with penalties reduced to 1/18 (approx. 1.67% of tax) if paid by 31 December 2026, rising to 1/9 by 31 March 2027. It covers income tax, VAT, IRAP, and withholding taxes. The CPB sheet provides a pre-calculated amount based on the taxpayer’s risk profile.
- Strategic Decision Point: Taxpayers must weigh the cost of maintaining CPB compliance (enhanced documentation, periodic reporting) against the substantial penalty protection and dispute prevention. The summary sheet includes a cost-benefit simulator. Advisors should run scenarios for each client before the October deadline.
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