Legislative Decree No. 148 of 7 August 2026, published in the Official Gazette on 11 August 2026, introduces 37 articles reshaping corporate income taxation, VAT administration, loss carry-forward rules, dividend withholding, and compliance frameworks, effective 12 August 2026.
The Italian Revenue Agency has announced that it published Legislative Decree No. 148 of 7 August 2026 (the Omnibus Tax Decree) in the Official Gazette on 11 August 2026.
This follows the Italian government’s approval of a sweeping 37-article tax reform on 4 August 2026, introducing changes across individual income, corporate taxation, VAT administration, and collaborative compliance.
The decree received provisional approval on 10 June 2026, was forwarded to the Senate on 21 July 2026, and entered into force on 12 August 2026.
The key provisions and measures are summarised below:
Corporate tax
Agricultural income and advanced cultivation systems: Agricultural income expanded to include product handling, conservation, and marketing (Article 2135, Civil Code) under Legislative Decree 192/2024. Advanced cultivation systems (vertical farms, hydroponic) now qualify on registered properties within cadastral categories C/1–C/7 and D/1, D/7–D/10. This modernises the treatment of non-traditional farming methods, recognising value-added agricultural activities beyond primary production.
Bond write-downs and capital losses: Bond write-downs for current assets now follow accounting principles rather than a fixed tax ceiling (Article 5, TUIR). Capital losses on fixed-asset bonds apply only if realised through sale or compensation, preventing deductions for unrealised valuation changes. This aligns tax treatment with economic reality and strengthens the connection between book and tax positions.
Share-based payment plans: Share-based payments (stock options, equity grants) are deductible upon vesting or liability settlement, proportional to options exercised. Companies can now match deduction timing with the economic event of employee compensation, improving cash flow and expense recognition alignment.
Goodwill, intangibles, and government grants: Goodwill, trademarks, and indefinite-life intangibles amortised over 18 years with required correlation to IAS/IFRS impairment losses. Government grants for research and development shift from cash to accrual accounting, bringing tax treatment into line with when economic benefit arises rather than the payment date.
Industrial holding company threshold: Industrial holding companies retain preferential treatment only when financial activities exceed 50% of total revenues. This explicit threshold clarifies which entities qualify for favourable income tax treatment under the industrial holding regime.
Loss carry-forward limits: Loss carry-forward limits apply upon a change in voting control or a shift in business activity (Article 84, TUIR; Article 2359, Civil Code). These restrictions prevent the acquisition of loss-carrying companies primarily for tax benefit harvesting, protecting the revenue base after ownership changes.
Extraordinary accounting and tax realignment: One-time extraordinary realignment allows retroactive accounting/tax value alignment for IRES and IRAP using Legislative Decree 192/2024 overall balance test. This optional measure lets companies correct historical discrepancies between book and tax positions in a single election. Effective from the tax period following 31 December 2025, with payment due by the income tax settlement deadline.
Cross-border loss transfers in EU/EEA mergers: Cross-border mergers in EU/EEA countries can transfer losses with proper information exchange (Article 181, TUIR). This enables loss pooling in multinational reorganisations, removing a previous barrier to loss utilisation in cross-border structures.
Global minimum tax and OECD/G20 regimes: Global minimum tax rules (15% effective rate) under Legislative Decree 209/2023, implementing EU Directive 2022/2523, adopt OECD/G20 simplified regimes. Amendments to Articles 18 and 21 plus new Article 39-bis streamline calculations for national and supplementary minimum tax. These rules ensure large multinational and national groups pay a minimum 15% effective tax in each jurisdiction, addressing profit shifting to low-tax countries.
VAT, assessment, and compliance frameworks
VAT deduction and invoice recording deadlines: VAT deduction deadlines (Article 19, paragraph 1, Presidential Decree 633/1972) and invoice recording deadlines (Article 25) both extend to the return for the second subsequent year. This extended window provides taxpayers greater flexibility in supporting documentation and reduces compliance pressure for year-end invoicing.
Collaborative compliance certification deadline extension: Collaborative compliance certification deadline (Legislative Decree 128/2015) extended from 30 September 2026 to 31 December 2026 for 2024–2025 periods (Article 17). This regime requires entities to maintain integrated tax risk detection systems; the extension accommodates implementation timelines. Penalty provisions tightened (Article 18, Legislative Decree 241/1997) to strengthen recovery of unpaid amounts identified through collaborative engagement.
Permanent establishment financial documentation: Permanent establishments must timestamp financial statements in tax returns from 2026 onward (Article 19, Article 152, TUIR). The timestamp requirement (via electronic means or equivalent) establishes document authenticity and prevents subsequent modification of reported positions.
Real estate assessment controls and flat-rate regime changes: Real estate assessment controls expanded to non-notary professionals (Article 20), capturing self-assessed mortgage and land registry taxes in advertising procedures. The flat-rate regime’s one-year shortened assessment deadline is removed from 2026 (Article 21), affecting e-invoice-only taxpayers. Special provisions address assessment of members with multi-year effectiveness, limited liability companies with restricted shareholder bases, and transactions deemed uneconomic.
Dividend withholding tax increases: European pension funds face a dividend withholding tax increase from 11% to 20% (Article 27, paragraph 3, Presidential Decree 600/1973), affecting the tax efficiency of cross-border pension investments. Unlisted shareholdings held in black-listed jurisdictions (privileged tax regimes) increase from 21% to 36% substitute tax with no instalment option, tightening treatment of opaque ownership structures.
Two-year preventive composition with creditors: Two-year preventive composition with creditors (Legislative Decree 13/2024) amended with revised exclusion criteria and forfeiture rules. This bankruptcy alternative regime—allowing businesses to negotiate debt settlements—gains refinements to clarify eligibility and renewal conditions.
Voluntary disclosure for ISA entities: Voluntary disclosure for ISA entities targeting 2020–2023 applies substitute tax on income, surtaxes, and IRAP with heightened relief for high-scoring Synthetic Reliability Index entities. Tax relief strengthens for 2020–2021 (COVID-affected years). Payment window runs 1 January through 15 March 2027 with up to ten monthly instalments. The program incentivises catching up on unpaid taxes from pandemic years at reduced rates.
Third Sector Entities IRAP classification: Third Sector Entities (TSEs) other than social enterprises now determine IRAP classification annually using Consolidated Law income tax rules, simplified via Article 82-bis, Legislative Decree 117/2017. This standardisation reduces administrative burden for nonprofits and eliminates separate IRAP classification procedures. Effective from 31 December 2025.
Electronic payment compliance tolerance threshold: A 5% tolerance threshold waives penalties for electronic payment discrepancies in daily fee transmission (Article 33, Legislative Decree 471/1997, Article 11, paragraph 2-quinquies and Article 12, paragraph 2). This de minimis allowance recognises system reconciliation delays and minor reporting variances, preventing penalties for immaterial deviations.
Personal tax
Dependent family members: Dependent family members no longer require cohabitation or court-ordered alimony to claim tax relief. Covers spouses, children, and relatives under Article 433 of the Civil Code meeting income thresholds. The removal of cohabitation and alimony prerequisites broadens eligibility, particularly for separated parents maintaining financial arrangements outside court systems. Effective retroactively from 20 December 2025.
Self-employment income from tax credit transfers: Self-employment income now includes gains from tax credit transfers and offsets (Article 121, Legislative Decree 34/2020) at a 26% substitute tax rate, unless qualifying as artistic/professional services. This captures gains when taxpayers sell or offset unused credits from incentive programs, with the 26% rate applying automatically except where the transaction constitutes payment for services rendered.
Fringe benefits for company vehicles: Fringe benefits for company vehicles revised to flat-rate treatment under Legislative Decree 19/2025 and Article 51, paragraph 4 of the TUIR. The shift from normal value taxation to a fixed formula simplifies compliance for employers and incentivises lower-emission vehicle provision.
