The Italian Revenue Agency has issued implementation guidance for the tax relief introduced by the 2026 Budget Law, setting out the conditions under which eligible employers can avoid the 10% additional tax on qualifying variable remuneration by making donations to eligible Third Sector entities.
The Italian Revenue Agency has issued a measure setting out the practical rules for claiming tax relief on bonuses and variable remuneration paid in the form of bonuses and stock options in the financial sector.
The measure, signed by the Director of the Italian Revenue Agency on 30 July 2026, provides guidance for employers seeking to benefit from the relief introduced by the 2026 Budget Law.
The relief applies to remuneration paid to executives and individuals engaged under coordinated and continuous collaboration agreements.
The measure implements Article 1, paragraph 137, of Law No. 199/2025, which inserted paragraph 2-ter into Article 33 of Decree-Law No. 78/2010. Under the new provision, where the statutory requirements are satisfied, the 10% additional tax on variable remuneration exceeding the fixed portion of salary does not apply to eligible taxpayers.
Paragraph 2-ter also required the Director of the Italian Revenue Agency to issue implementation rules setting out how eligible taxpayers may access the relief.
Relief dependent on donations to Third Sector entities
The guidance states that access to the preferential tax regime is conditional on the payer of the variable remuneration making a payment to one or more Third Sector entities governed by Legislative Decree No. 117/2017 (Third Sector Code).
The payment must equal at least twice the total amount of the additional tax due for the relevant tax period. The calculation must be based on the full amount of the additional tax that would otherwise be payable.
The measure also requires the recipient organisations to be independent of the payer. As a result, entities that control the donor, are controlled by the donor, or belong to the same group under common control are not eligible to receive the qualifying payments.
Payment rules and additional contribution option
According to the guidance, donations qualifying for the relief must generally be made by bank transfer.
However, payments made before the publication of the measure using other methods will also be recognised, provided they are traceable and properly recorded by the beneficiary entity.
The measure also provides a safeguard where year-end adjustments show that the amount already paid falls below the statutory minimum of twice the additional tax due. In those circumstances, the payer may preserve the relief by making an additional payment to the Third Sector entities within 60 days from the deadline established by Article 4, paragraph 6-quater, of Presidential Decree No. 322/1998 for submission of the Certificazione Unica.
Reporting and record-keeping obligations
Employers granting eligible stock options and bonuses must include in their income tax return both the total value of the qualifying payments and the tax identification numbers of the beneficiary entities.
They must also retain documentation demonstrating both the total additional tax due and the amounts actually paid.
In addition, the withholding agent must certify in the Certificazione Unica (CU) issued to executives and coordinated and continuous collaborators receiving the variable remuneration that the 10% additional tax rate has not been applied in accordance with Article 33, paragraph 2-ter.
Effective date and transitional arrangements
The implementation rules apply to variable remuneration paid from 1 January 2026.
As the Redditi income tax return form incorporating the new reporting requirements will only be approved in 2027, the measure introduces transitional arrangements for 2026.
Payments made from 1 January 2026 until the end of the tax period, where that tax period ends before 31 December 2026, must be reported in the Redditi form to be approved in 2027. The same return must also include payments made during the tax period in progress as of 31 December 2026.
