DGTAX News 27 - 2026 - FLASH

Tax payments – Permanent establishment: legally recognized date for the REDDITI 2027 return – Global Minimum Tax: the Agency’s clarifications on the GloBE declaration

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Tax payments

Income tax (IRPEF, IRES and IRAP) is paid in two instalments using F24 payment form:

  1. Balance from the previous year.
  2. Advance payment for the following year.

Special Extension 2026 (VAT-registered businesses, SRIs, flat-rate schemes)

For those carrying out economic activities (SRIs taxpayers, flat-rate and minimum tax schemes):

  • By 20 July 2026: payment without surcharges.
  • Within the following 30 days: payment subject to a 0.80% surcharge .

Individuals (Redditi PF form) without a VAT number

  • Balance + First advance payment: by 30 June (or within the following 30 days, subject to a surcharge of 0.40%). Payment may be spread in instalments until 16 December.
  • Second advance payment: by 30 November (cannot be paid in instalments).

The advance payment is calculated as follows: the first instalment, amounting to 40 per cent, is due in June (50 per cent for SRIs taxpayers), and the second, amounting to 60 per cent, is due in November (50 per cent for SRIs taxpayers).

Partnerships

  • They do not pay personal income tax (which is payable by the individual shareholders).
  • They pay only IRAP directly.

Limited Companies

  • Balance + First advance payment: by the last day of the 6th month following the end of the financial year (30 June for financial years coinciding with the calendar year, subject to the special extension referred to above). If the financial statements are approved more than four months late, the deadline is extended to the last day of the month following approval.
  • Second advance payment: by the last day ofthe 11th month following the end of the financial year.

The advance payment is calculated as follows: a first instalment of 50% in June (40% for those who do not apply the SRIs) and a second instalment of 50% in November (60% for those who do not apply the SRIs).

Permanent establishment: legally recognized date for the REDDITI 2027 tax return

Among the new provisions of the fourth amending decree of the tax reform (the so-called ‘Omnibus’ decree), which was approved at a preliminary reading by the Council of Ministers on 10 June 2026, Article 18 amends Article 152 of the TUIR with regard to the obligations of non-resident companies with a permanent establishment in Italy.

The amendment is purely procedural in nature and leaves the substantive framework of the provision unchanged (the criteria for determining income, the ‘functionally separate entity’ principle, the requirements regarding the adequacy of the endowment fund, and the arm’s-length valuation).

In practical terms: the income statement and balance sheet used to determine taxable income in Italy must be given a certified date by the deadline for submitting the tax return for the relevant tax year, by means of a time stamp or another suitable method provided for by law; the relevant data must also be included in a specific section of the tax return (most likely in section RS).

The measure aims to fill a gap: unlike the financial statements of limited companies, the financial statements of a permanent establishment are not subject to any form of public disclosure, as they serve primarily a tax-related purpose; the aim is therefore to ensure their authenticity and provide greater certainty in dealings with the tax authorities.

If confirmed in the final text, the new rules will apply from the tax year ending on 31 December 2026 (first application via the 2027 REDDITI return), whilst for 2025 the current rules remain in force, which do not require the accounting results of the permanent establishment to be shown separately.

Global Minimum Tax (Pillar II): the Agency’s guidance on the GloBE Declaration

As the first deadline set out in the legislation approaches – 30 June 2026 for entities 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 containing frequently asked questions (FAQs), which provides detailed clarifications on certain particularly significant operational aspects.

These clarifications will certainly be of interest to those within your organisation, or acting on your behalf, who are responsible for overseeing and ensuring the correct and timely fulfilment of the relevant obligation: there is an obligation to express all amounts exclusively in euros and to ensure full consistency with the data in the Relevant Communication (GIR). It is also clarified that access to the simplified schemes (Safe Harbour) reduces the number of sections to be completed, but never removes the obligation to submit the form.

Photo Credits: Andrea Cherchi
https://it-it.facebook.com/andreacherchimilano
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