Sommario
Regularisation of an omitted Global Minimum Tax return
In an FAQ dated 17 July 2026, the Italian Revenue Agency clarified that notifications and returns submitted late under the Global Minimum Tax scheme may be regularised through voluntary disclosure and, in the case of the relevant notification, the delay does not result in the loss of access to the optional schemes, including the Transitional CbCR Safe Harbour.
The Agency refers to the standard rules laid down in Presidential Decree 322/1998. A return submitted within 90 days of the deadline is considered late and may be regularised through voluntary disclosure, thereby qualifying for the reduction in penalties provided for in Article 13 of Legislative Decree 472/1997.
Conversely, a return submitted after the 90th day is deemed not to have been filed and is not eligible for the reduction in penalties provided for under the voluntary disclosure scheme. The transitional regime provided for under the GloBE rules remains applicable, however. For the first three financial years of application (2024–2026), no administrative penalties will be imposed, except in cases of wilful misconduct or gross negligence.
New Register of Beneficial Owners
On 23 July 2026, the new Register of Beneficial Owners (Legislative Decree 122/2026) came into force, transposing EU Directive 2024/1640, which aims to bring national legislation into line with EU directives on transparency and anti-money laundering.
The new system redefines access to information, making it conditional upon the existence of a legitimate and qualified interest — presumed for certain categories, such as professional journalists, or to be demonstrated on a case-by-case basis for the prevention of financial crimes — as assessed by the Chamber of Commerce, which may refuse access in exceptional circumstances to protect the beneficial owner (such as security risks or the presence of minors).
However, for the regulations to come into effect in practice, it will be necessary to await the issuance of the relevant implementing decrees by the MIMIT and the updating of the technical specifications – an administrative process that is expected to be completed before the Council of State’s final ruling, scheduled for May 2027.
Company cars for mixed use: the latest on taxation
The draft decree amending the tax reform (the Omnibus Decree) changes the rules for calculating the taxable value (fringe benefit) for company cars provided to employees for mixed use.
Vehicles over 5 years old
- 50% increase in the taxable base: in order to discourage the use of older vehicles and encourage companies to renew their fleets, from the fifth year following first registration, the taxable value of the fringe benefit is increased by 50% on top of the base value (calculated using the ACI tables);
- Internal reallocations: the surcharge is linked to the vehicle’s actual age, regardless of the number of employees to whom the car may have been reallocated over time.
Surcharge for accessories and optional extras
- A 5% surcharge on the taxable amount is applied for accessories, optional extras and additional fittings that are not expressly valued in the ACI tables.
Transitional arrangements
- Safeguards and an extension of the transitional arrangements are introduced for cars already ordered by 31 December 2024 and made available for use during 2025.
Implications for businesses and employees
- Employers and fleet managers are required to carry out a detailed review of their company car fleets in order to comply with the new rules and optimise the management of costs and staff payroll.
Suspension of tax notices in August
In a press release, the Italian Revenue Agency and the Italian Revenue Agency – Collection (AdeR) have denied press reports concerning an unusual concentration of notifications in the months leading up to the summer break.
Please also bear in mind that:
- Formal checks and appeals: the Agency accepts documents submitted after the 30-day deadline, and the time limits for challenging tax assessment notices and other notices are suspended for the whole of August.As the first deadline set by the legislation approaches – 30 June 2026 for those whose tax year coincides with the calendar year – we feel it is both necessary and useful to bring an important update to your attention. The Italian Revenue Agency has in fact recently published a dedicated section on its official website devoted to frequently asked questions (FAQs), which provides detailed clarifications on certain operational aspects of particular importance;
- August suspension: AdeR is suspending notifications for the whole of August, except for urgent and unavoidable matters;
- Compliance letters: they do not have a strict expiry date, and it is possible to initiate contact with the relevant departments even after August;
- Notifications of irregularities: the deadline for responding or paying has been extended to 60 days (with the option to pay in instalments over up to 5 years) and is suspended from 1 August to 4 September.
Please also note that, as is the case every year, tax obligations and payments via the F24 form due within the first twenty days of August are deferred to the 20th of the month.