Sommario
Consolidated Act on Compliance and Assessment
Following its publication in the Official Gazette No. 181 of 6 August 2026, Legislative Decree No. 141 of 5 August 2026, which approves the Consolidated Act on legislative provisions concerning compliance and assessment, came into force the following day. This is the final Consolidated Act provided for by the reform: its provisions apply with effect from1 January 2027.
Whilst it does not introduce any new substantive obligations, the decree accompanies the recodification with a number of corrections and coordinating provisions. In day-to-day practice, it will therefore be necessary to distinguish between mere renumbering and substantive amendments.
Omnibus Decree: changes coming into force on 12 August
Legislative Decree No. 148 of 7 August 2026 sets out supplementary and amending provisions concerning income tax, inheritance and gift tax, VAT, excise duties, audits, cooperative compliance and simplification.
VAT deduction: the two-year time limit is back
Article 12 extends the deadline for exercising the right to deduct, and for recording purchase invoices, to the second year following the year in which the invoice was received, rather than the calendar year limit. The amendment applies to both Presidential Decree 633/1972 and the new Consolidated VAT Act (Legislative Decree 10/2026) and brings domestic legislation into line with EU principles.
Company cars for mixed use: confirmations and adjustments
Article 2 confirms the flat-rate taxation based on the ACI tables (50 per cent of the standard cost per kilometre, reduced to 10 per cent for electric vehicles and 20 per cent for plug-in hybrids) and the 50 per cent increase in the taxable value with effect from 31 December of the fifth year following first registration.
The flat-rate surcharge of 5 per cent for accessories and fittings not included in the ACI tables and not purchased directly by the employee has also been confirmed, net of any sums withheld from the employee, and the extension of the safeguard clause for vehicles ordered by 31 December 2024 to also cover cases where the vehicle is reallocated to an employee other than the original assignee.
The new scheme applies from the 2026 tax year, including 2025 allocations not covered by the safeguard; the actions taken by employers up to 31 December 2025 remain valid, with no refund of any excess tax paid.
Two-year composition with creditors: renewal and incentives
Those who renew their composition-with-creditors arrangement for the two-year period 2026–2027 retain the following benefits: exemption from the compliance certificate requirement for offsets of up to €100,000 per annum for VAT liabilities and €70,000 for direct taxes and IRAP; a two-year extension of the limitation periods for tax assessments; and no interest on instalment payments. Furthermore, the grounds for termination have been simplified and are now based on a verified discrepancy of at least 30 per cent between declared and agreed revenue or remuneration, or on other non-minor breaches.
The new voluntary disclosure scheme for the years 2020–2023
Article 29 introduces a special voluntary disclosure scheme reserved for ISA taxpayers who renew their participation in the settlement scheme for the two-year period 2026–2027. It is possible to regularise the tax liabilities for the years 2020 to 2023 by paying a substitute tax calculated on the basis of an increase in the income already declared, the amount of which varies according to the ISA score.
Tax assessment: lack of economic viability and closely held companies
Two provisions are of particular relevance from a defence perspective. Article 24 restricts the assessment based solely on the uneconomic nature of the transaction: the discrepancy between the consideration and the market value must be accompanied by further serious, precise and consistent circumstantial evidence, or be manifest and significant. Article 23 restricts the presumption of profit distribution in closely held companies to cases where unrecorded positive items or non-deductible negative items—which are non-existent—are established.
It should be noted, on the other hand, Article 21, which removes the one-year reduction in the assessment period provided for ‘compliant’ taxpayers under Article 1, paragraph 74, of Law 190/2014, with effect from the 2026 tax year.
Electronic payments: 5 per cent exemption
Article 33 introduces a tolerance threshold of 5 per cent between the electronic payment transactions recorded for the purposes of reporting daily takings and the electronic payments actually accepted: where the discrepancy is less than this, no penalties shall be imposed for failure to report, incorrect reporting or late reporting.
Local taxation: online IMU return
Legislative Decree No. 147/2026, which came into force on 12 August, subject to deferred commencement dates for individual provisions, reorganises the framework governing regional and local taxes and regional fiscal federalism.
In terms of compliance, theIMU return will now be submittedexclusively online, with a deadline of 30 June. Finally, a new development of immediate practical interest concerns discounts for automatic payment: local authorities will be able to grant reductions in tax rates or charges to taxpayers who opt for direct debit from their current account, calculated as a percentage – possibly subject to a maximum amount – or as a fixed sum.
Failure to submit a VAT return: the new automated assessment
By Order No. 239129 of 28 August 2026, the Italian Revenue Agency set out the operational procedures for Article 54-bis.1 of Presidential Decree 633/1972, introduced by the 2026 Budget Law (Law 199/2025). The provision allows the tax authorities to assess VAT even in the event of failure to submit the annual return, by means of automated procedures and using electronic invoices, electronic payment records, LIPE statements and payments already made by the taxpayer. The notification may be issued by 31 December of the seventh year following the year in which the return should have been filed.
VAT in the digital age: initial approval for the ViDA decree
At its meeting on 4 August 2026, the Council of Ministers gave its preliminary approval to the draft legislative decree transposing Article 2 of Directive (EU) 2025/516, one of the measures comprising the ViDA package. The provisions will apply from 1 January 2027 and primarily concern distance selling, electronic platforms, the OSS and IOSS schemes, and the Single VAT Registration scheme.
The draft sets out the rules governing sales made via platforms, portals and online marketplaces, with reference to the ‘deemed supplier’ mechanism; it amends the calculation of the €10,000 threshold above which tax is due in the country of destination; and it addresses the coordination between special VAT schemes and the small business scheme, as well as on refund procedures. The draft also provides for the gradual phasing out of the call-off stock scheme. The opinions of the parliamentary committees are still to be obtained before the second reading in the Council of Ministers.
Capital Goods 4.0: deadlines for notifications extended to 15 September
A decree issued by the Ministry of Enterprise and Made in Italy on 31 July 2026 formallyextendedthedeadlinefor submitting completion notifications relating to investments in Industry 4.0 capital goods to 15 September 2026.