Resolution No. 14 establishes code "7079" for businesses receiving partial funding under the depleted Transition 5.0 programme, while Resolution No. 15 renames CFC codes to reflect the new 15% minimum tax threshold on foreign subsidiaries.
The Italian Revenue Agency has introduced new tax codes to facilitate payments under two distinct fiscal frameworks: the Transition 5.0 plan and the reformed controlled foreign companies (CFC) regime. These updates aim to streamline tax compliance for businesses navigating recent legislative changes.
Transition 5.0: New code for partial credit
Resolution No. 14 of 16 April 2026 establishes tax code “7079” for companies eligible under the Transition 5.0 initiative. This credit, worth 89.77% of the originally requested amount, is available exclusively to businesses that received technical approval from the Energy Services Manager (GSE) but were notified that funding had been exhausted.
The measure, introduced under Article 8 of Legislative Decree No. 38/2026, applies only to 2026 and covers investments listed in Annexes A and B of Law No. 232/2016, as well as staff training expenses. Eligible companies must have already submitted communications under Article 38, paragraph 10, of Legislative Decree No. 19/2024 and completed the verification process with GSE.
The decision to provide a reduced credit reflects the government’s response to depleted funding. Rather than leaving approved companies without support, the legislator allocated the remaining resources to those that had already completed reporting and technical validation, thereby partially covering investments already made.
How to use the new code
The credit can only be offset via F24 forms submitted by 31 December 2026. Companies must enter code “7079” in the Treasury section of the form, indicating the credit amount in the “Offsetted credit amounts” column. In cases requiring repayment of the benefit, the same code should be used in the “Paid debit amounts” column.
The reference year must be entered in “YYYY” format, matching the year of investment completion as displayed in the beneficiary’s tax drawer. Each company can verify their available credit amount through their online tax drawer, based on information transmitted by GSE to the Revenue Agency.
During processing, the Agency verifies that taxpayers appear on GSE’s beneficiary list and that offset amounts do not exceed authorised limits. Forms failing these checks will be rejected, taking into account any subsequent corrections communicated by the Manager.
CFC tax codes renamed after legislative changes
Resolution No. 15/2026 updates tax codes for the optional alternative tax regime governing controlled foreign companies. The revision reflects changes made by Legislative Decree No. 84/2025, converted into Law No. 108/2025, which restructured how foreign subsidiaries’ taxation is assessed.
Under the new framework, effective taxation of foreign subsidiaries is considered appropriate when controlling entities pay an amount equal to 15% of the net accounting profit for the financial year. This mechanism aligns with Articles 7 and 8 of Council Directive (EU) No. 2016/1164 of 12 July 2016, simplifying the determination of foreign tax burden while ensuring compliance with minimum global tax levels.
Updated payment codes
The renamed codes are:
- IRPEF subjects: 4077 (first advance instalment), 4078 (second advance or single payment), 4079 (balance)
- IRES subjects: 4080 (first advance instalment), 4081 (second advance or single payment), 4082 (balance)
These codes replace those established in Resolution No. 64/2024. The Agency confirmed that payments must be made within the deadlines and according to the methods established for income taxes. Importantly, the renaming does not alter the technical substance of the requirement—all previous guidance on completing F24 forms contained in Resolution No. 64/2024 remains valid.
This measure ensures taxpayers have the necessary formal consistency between the current regulatory framework and payment instruments, facilitating tax management of international holdings during this transition phase.
