Building Renovations: What will change in 2025 and 2026
Knowing good advice 2025 marks the definitive end of credit transfers and invoice discounts for almost all building bonuses, following Law Decree 212/2023, converted into Law 17/2024. The concessions therefore return to ‘ordinary’ management, with tax deductions only available in tax returns. Law 207/2024 (2025 budget law), with clarifications from Inland Revenue Circular No. 8 dated 19th June 2025, and the most recent updates provided for in the 2026 budget bill, have revised the tax benefits as follows. For renovations pursuant to Article 16-bis of the TUIR (Consolidated Income Tax Law), the 50% deduction remains confirmed from 2025 only for the main residence and related appurtenances, while for other residences it returns to 36%, with a maximum expenditure limit of Euro 96,000 per property unit. This measure has currently been extended to 2026.Family members living with the owner of the main residence, if they have incurred the expenses, will no longer be able to benefit from the 50% deduction as in the past, but the benefit will be reduced to 36% from 2025. The deduction percentages for the Ecobonus and Sismabonus have also been standardized for 2025 and 2026 in a similar way to the deduction percentages and spending limits for renovation work. The Furniture Bonus, which is available for the purchase of furniture/large appliances for properties undergoing renovation, is set at 50% within the spending limit of Euro 5,000 for the years 2025 and 2026. For the Superbonus, on the other hand, for Sismabonus and Ecobonus interventions, without prejudice to the spending limits provided for individual interventions and not considering the numerous exceptions, the deduction percentages are set at 65% for 2025. Please note that for all work involving energy savings, the obligation to send a communication to ENEA remains unchanged. Currently, a general restructuring of the rates for all types of interventions for the year 2027 is already planned; this will be discussed in more detail in a subsequent article. Date of publication Author Areas of activity Assistenza Fiscale (9) Assistenza Legale (2) Consulenza del lavoro (3) Kreston-TDL (1)
Update on the implementation of tax reform
Knowing good advice Law No. 120 dated 8th August 2025, was published in the Official Gazette No. 184 dated 9th August 2025, amending Law No. 111 dated 9th August 2023, on “Authorisation to the Government for tax reform”. Law No. 111 dated 9th August 2023, authorised the Government to adopt one or more legislative decrees revising the tax system in accordance with constitutional principles and European Union and international law, based on the general and specific principles and guidelines set out in the Law itself. Initially, the Government had 24 months to complete the regulatory framework, meaning that the reform had to be completed by 29th August 2025. This deadline has recently been extended by one year (29th August 2026), as a result of the amendment provided for by Law No. 120 dated 8th August 2025. 120. A comprehensive reorganization of the provisions governing the tax system is also planned, through the drafting of consolidated texts. In the initial version, these texts were to be approved by 29th August 2024; the deadline was ultimately extended to 31st December 2026, as a result of the extension of the aforementioned Law No. 120/2025. 120/2025. In addition, a tax code containing the rules governing individual taxes will be prepared in order to simplify the tax system and increase the clarity and accessibility of tax regulations. This objective must be implemented within 12 months of the date of entry into force of the last of the legislative decrees relating to the reform. It should be noted that a number of legislative decrees have been preliminarily approved containing provisions on: the tertiary sector, business crises, and VAT; IRPEF (Personal Income Tax) and IRES (Corporate Income Tax), international taxation, inheritance and gift tax, registration tax, as well as amendments to the Taxpayers’ Charter and the Consolidated Tax Laws regional and local taxes and regional fiscal federalism. A special commission has recently been set up, whose members have been appointed by the Minister of the Higher Council of Economy and Finance to draft the new body of legislation. Date of publication Author Areas of activity Assistenza Fiscale (9) Assistenza Legale (2) Consulenza del lavoro (3) Kreston-TDL (1)
The Call-off Stock Regime: Regulations, Conditions, and Practical Application
Knowing good advice The call-off stock regime simplifies intra-Community transactions by allowing the supplier to transfer goods to another Member State without immediately carrying out a supply. Discover the requirements, timeframes, and tax implications for managing these transactions correctly. The call-off stock regime, governed by Legislative Decree No. 192 dated 5th November 2021 (which implements Article 17-bis of Directive 2006/112/EC), applies when a taxable subject transfers goods to a warehouse located in another EU Member State. In this case, the intended buyer is already identified (both in terms of identity and VAT identification number) at the time of transport and can remove the goods from the warehouse at a later time, acquiring ownership of them. The regime provides that: a) no intra-Community supply or intra-Community acquisition occurs at the time of dispatch or transport of the goods to the warehouse located in another Member State; b) the exempt intra-Community supply (in the Member State of departure) and the taxed intra-Community acquisition (in the Member State of arrival) occur only when the buyer removes the goods and acquires ownership of them. Conditions for applying the call-off stock regime To correctly apply the call-off stock regime, the following conditions must be met: The supplier and the intended buyer must be VAT taxable subjects. The supplier has not established its business establishment or a permanent establishment in the Member State of destination. The supplier must record the dispatch or transport of the goods in a special register. The goods must be transported from one Member State to another for subsequent supply to the intended buyer. The supplier must indicate the buyer’s VAT identification number in the INTRASTAT summary statement for the period in which the shipment occurs. The intended buyer must be identified for VAT purposes in the Member State of arrival. The buyer’s identity and VAT identification number must be known to the supplier at the time of shipment or transport. Completion of the intra-Community supply The intra-Community supply is also considered to have been completed in the following residual cases: The day after the expiry of 12 months from the arrival of the goods if they have not yet been supplied. When, within 12 months of arrival, one of the conditions set out in Article 41-bis, paragraph 1, ceases to be met. Before the supply, if within 12 months the goods are sold to a person other than the original buyer. Before shipment to another Member State, if the goods are further transported within 12 months. Loss of Tax Neutrality The tax neutrality regime lapses in the following cases: Destruction, loss, or theft of the goods. Replacement of the original purchaser, even if the call-off stock conditions and registration requirements are met. Sale of the goods to another Member State. Date of publication Author Areas of activity Assistenza Fiscale (7) Assistenza Legale (2) Consulenza del lavoro (2) Kreston-TDL (1)
Biennial Preventive Composition with Creditors: What it is, how it works, and what’s changing in 2025-2026
Knowing good advice The Biennial Preventive Composition with Creditors (CPB) is a measure introduced by Legislative Decree No. 13 dated 12th February 2024, to provide greater tax certainty and stability to professionals and businesses. This new measure, designed for those with business or self-employed income, allows such subjects to agree in advance with the Italian Inland Revenue Agency on their taxable income and net production value for the two-year period following adherence, on which taxes will be calculated. The Objectives of the Two-Year Preventive Composition with Creditors The CPB is part of a broader tax simplification process and aims to: Improve the relationship between taxpayers and the tax authorities Promote tax transparency Promote compliance with the Summary Reliability Indices (ISA) Reduce uncertainty related to potential audits Promote medium-term tax planning Renewal for the 2025-2026 two-year period: what the MEF provides In implementation of Article 9 of Legislative Decree 13/2024, the Ministry of Economy and Finance approved the new methodology for developing composition with creditors proposals for the 2025-2026 period with decree dated 28th April 2025. The implementing provision was published in the Official Gazette No. 117 dated 22nd May 2025 , making the new phase of the CPB operational. Who is eligible for the Two-Year Preventive Composition with Creditors? The legislation identifies three main categories of taxpayers: Those who have already joined the CPB for 2024-2025 Persons who accepted the proposal for the 2024-2025 two-year period do not need to renew their adherence for 2025: the composition with creditors regime will continue automatically, provided that the initial requirements remain met. New adherents for 2025-2026 Those who did not join the CPB in 2024 can now consider joining for the new two-year period 2025-2026.Acceptance of the proposal will take place via ISA tools, following the procedures defined by the MEF Decree, by 30th September 2025. Adherence for the 2026-2027 two-year period As provided forby Article 14 of Legislative Decree no. 13/2024 13/2024, once the first two-year period has concluded, if the requirements persist and no impediments arise, the Italian Inland Revenue Agency can formulate a new composition agreement proposal for the two-year period 2026-2027. Flat-rate taxpayers excluded from the CPB for 2025-2026 Participation in the CPB was experimented in 2024 for flat-rate taxpayers. However, for the two-year period 2025-2026, this option was not renewed: flat-rate taxpayers, therefore, remain excluded from the application of the composition agreement. Date of publication Author Areas of activity Assistenza Fiscale (7) Assistenza Legale (2) Consulenza del lavoro (2) Kreston-TDL (1)
Company car assigned to employees: mixed use, tax implications, and operating procedures
Knowing good advice a) Assignment of a car for mixed use The assignment of company cars to employees for mixed use is one of the most common forms of fringe benefits in Italy. It is a formula that allows the employee to use the company vehicle—typically a car, but sometimes also a motorcycle or scooter—both for work-related needs (travel, visiting customers or suppliers) and for personal purposes, such as weekends or leisure time. Hence the term “mixed use.” Company policies and formal agreements Vehicle assignment is governed by company policies that establish the terms of use, limitations, and any employee responsibilities. It is standard practice to prepare a formal communication informing the employee of the type of vehicle assigned, the conditions of use, and, where applicable, any amounts to be withheld from their payslips to cover costs exceeding company limits (e.g., choosing a higher-end vehicle, requesting additional accessories, etc.). Tax and Social Security Implications Given that the vehicle is used for both work and personal purposes, it effectively constitutes a marginal benefit for the employee, as they have the opportunity to enjoy an asset whose cost is borne by the employer, but which can also be freely used for personal and family needs. This benefit therefore has a tax and social security impact that must be quantified and managed. The quantification must first begin with an analysis that breaks down two distinct categories: The tax exemption limits for fringe benefits; The criteria for determining the economic value of the car benefit granted to the employee. Exemption Limits:According to the 2025 Budget Law (Law No. 207/2024), until 2027, the tax and social security exemption threshold for fringe benefits is equal to: Euro 000 for all workers; Euro 000 for workers with dependent children. If the total value of the car benefit (plus any other fringe benefits) is less than the established limit, there is no tax or social security impact. If it exceeds the limit, the entire amount becomes taxable. Consequences for the employer:In addition to the impact on the employee’s net pay, exceeding the limits also entails increased costs for the company, in terms of social security contributions and indirect costs. How is the value of the car benefit determined? The applicable legislation is Article 51, paragraph 4 of the TUIR (Consolidated Income Tax Act), which has been updated several times by the legislator to include environmental parameters in determining the benefit value. Below is a summary of the applicable criteria, broken down by period: Allocations until June 30, 2020Taxation of 30% on a conventional mileage of 15,000 km based on the ACI (Italian Automobile Club) mileage rate, net of any amounts withheld from the employee. Registration by 30th June 2020, allocation from 1st July 2020 to 31st December 2024Calculation of the normal value pursuant to Article 9 of the TUIR (leasing/rental rates), net of the portion related to business use. Registration and allocation from 1st July 2020 to 31st December 2024Variable percentage tax based on the vehicle’s pollution level, calculated on a standard mileage of 15,000 km based on the ACI (Italian Automobile Club) mileage rate, net of amounts withheld from the employee. Vehicle order by 31st December 2024, allocation from 1st January 2025 to 30th June 2025 Variable percentage tax based on the vehicle’s pollution level, calculated on a standard mileage of 15,000 km based on the ACI mileage rate tables, net of any amounts withheld from the employee. Order by 31st December 2024, allocation from 1st July 2025Variable tax from 10% to 50% depending on the vehicle’s drive system (electric, hybrid, gasoline, etc.) calculated on a standard mileage of 15,000 km based on the ACI mileage rate tables, net of any amounts withheld from the employee; Order, registration, and allocation from 1st January 2025Variable tax rate from 10% to 50% depending on the vehicle’s drivetrain (electric, hybrid, gasoline, etc.) calculated on a conventional mileage of 15,000 km based on the ACI mileage rate tables, net of amounts withheld from the employee. Interpretative doubts still open Some aspects remain unclear, including: What happens if the car was already in the company fleet but is allocated to a new employee in 2025? When should the normal value pursuant to Article 9 of the TUIR be adopted? On this last point, the Italian Inland Revenue Agency has previously clarified that in cases of leasing after 1st July 2020, with a vehicle registered before, the normal value of the asset must be applied, excluding the portion related to business use. This approach, however, presents several operational and management difficulties. An official clarification from the Italian Inland Revenue Agency remains desirable. b) Vehicle assignment without mixed use. What if the car is granted solely for business purposes? Finally, it is possible for the car to be allocated exclusively for business use. In this case, the employee accesses the vehicle only during working hours and leaves it at the company at the end of the day, returning home in another personal vehicle. Any personal use is prohibited and can result in disciplinary action. For the protection of the company, it is recommended that the employee sign a document clearly specifying all the rules of use. Date of publication Author Areas of activity Assistenza Fiscale (7) Assistenza Legale (2) Consulenza del lavoro (2) Kreston-TDL (1)
Legal collection and waiver of dividends: the italian Inland Revenue Agency clarifies with answer no. 59/2025 59/2025
Knowing good advice In its response torequest no. 59 dated 3 March 2025, the Italian Inland Revenue Agency addresses the issue of legal collection in relation to the waiver of dividends by shareholders, particularly when the dividends have already been approved by the company. In the case under analysis, the applicant company reports that: having approved the distribution of dividends when approving the 2020 financial statements; never having paid out the approved amounts; wishing to proceed with only a partial distribution of the approved dividends; having received confirmation from the shareholders (natural persons who are not entrepreneurs) that they waive the remaining portion, so that this amount can be allocated to the extraordinary reserve. Firstly, it should be noted that the legal collection argument is based on the principle that the sums waived by the shareholder have the same tax effect as if they had first been collected and then returned by the shareholder. More specifically, the waiver of receivables relating to income subject to cash taxation (such as directors’ remuneration) presupposes the legal collection of the receivable and therefore entails the obligation to tax such amounts, including through withholding tax (see Ministerial Circular No. 73/1994 and Inland Revenue Agency Resolution No. 124/2017). Returning to the specific case, the company retained that the dividend waived by a shareholder who was a natural person and not an entrepreneur did not generate any active tax effect, constituting a contingent asset under Article 88, paragraph 4-bis, of the TUIR. This position is based on the principle that the waiver does not alter the tax value of the shareholding, as confirmed by the Court of Cassation in its ruling no. 16595/2023. 16595/2023. However, in its response no. 59/2025, the Inland Revenue Agency reaches different conclusions, stating that this rule is not applicable to individual shareholders who are not entrepreneurs, as there is no difference between the tax value and the nominal value of the credit waived. In these cases, there is an increase in the tax value of the shareholding, with the consequent absence of taxable extraordinary income for IRES purposes. Finally, the Tax Office clarifies that waived dividends must be considered legally collected, making it necessary to apply the 26% withholding tax, without any obligation for the company to subject any extraordinary income to taxation. Date of publication Author Areas of activity Assistenza Fiscale (4)
Milleproroghe (Law Decree no. 202 dated 27 December 2024): conversion into law no. 15 dated 21 February 2025 – Main tax and regulatory changes
Knowing good advice Law Decree No. 202 dated 27 December 2024 (the ‘Milleproroghe’ decree) was converted into Law No. 15 dated 21.2.2025, published in the Official Gazette No. 45 dated 24.2.2025, which came into force on 25.2.2025, introducing significant changes to the original text. Main provisions Scrapping of tax collection notices – Readmission due to forfeiture Paragraphs 1-2 of Article 3-bis of Law Decree 202/2024, inserted during conversion, provided for readmission to the ‘scrapping of tax collection notices’ under Law 197/2022 (2023 Budget Law) for taxpayers who: Had submitted an application by 30 June 2023 Had forfeited their rights on 31 December 2024 due to irregularities in payments Had debts entrusted to Collection Agents between 1 January 2000 and 30 June 2022 Remote meetings – Extension to 31 December 2025 Paragraph 14-sexies of Article 3, introduced during conversion, extended the use of emergency regulations for meetings of companies, associations and foundations (Article 106 of Law Decree 18/2020) to 31 December 2025, previously expiring on 31 December 2024. Tax Credit Transition 5.0 – Retroactivity Article 13, paragraph 1-quinquies, inserted during conversion, amended Article 38, paragraph 2, of Law Decree 19/2024, making investments incurred before the submission of the application for access eligible for the tax credit Transition 5.0, provided they were made on or after 1 January 2024. Deadlines to be monitored by businesses Catastrophic risk insurance – Extension to 31 March 2025 Article 13, paragraph 1 extends the deadline for the mandatory stipulation of catastrophe insurance policies by companies registered in the Register of Trading Companies to cover damage to land, buildings, plants, machinery and equipment from 31 December 2024 to 31 March 2025. National Electronic Waste Traceability Register (RENTRI) – New Deadlines Article 11, paragraph 2-bis, inserted during conversion, provides for the extension from 60 to 120 days of the deadline for registration with RENTRI. For initial producers of special waste with more than 50 employees and other obligated parties, registration must take place between 15 December 2024 and 14 April 2025 (previously 13 February 2025). Date of publication Author Areas of activity Assistenza Fiscale (4)
New rules on payment traceability: changes introduced by the 2025 Budget Law
Knowing good advice The 2025 Budget Law introduced important changes to the Consolidated Income Tax Law (TUIR) regarding payment traceability (Art. 1, paragraphs 81-83, Law No. 207 dated 30 December 2024). Starting from 1 January 2025, expenses incurred for food, accommodation and transport during business trips by employees or collaborators will only be deductible if paid for using traceable payment methods. Which expenses are involved? The new provisions concern expenses incurred for: – Food and accommodation during business trips; – Analytical reimbursements for travel and transport expenses, including those incurred by taxi or private hire vehicle with driver; – Entertainment expenses incurred by companies for promotional and networking activities. These expenses will only be deductible if payment is made using traceable means such as credit cards, debit cards or bank transfers (Art. 23, Legislative Decree 241/1997). What are the consequences for companies and employees? Failure to use traceable payment methods will result in tax penalties for companies, self-employed workers and employees. Let’s look at the details: Non-deductibility of expenses for businesses and self-employed workers Expenses for food, accommodation, non-scheduled transport and entertainment will not be deductible from taxable income for IRES and IRAP purposes, irrespective of the nature of the expense or the context in which it was incurred. Taxation of reimbursements for employees Expenses incurred by employees during business trips, if reimbursed by the employer without adequate traceability, will be considered taxable income and therefore taxed as income from employment. Critical issues and compliance requirements for companies These new provisions require companies to adapt quickly to avoid tax penalties and problems in managing reimbursements. The main critical issues include: – Lack of detailed guidelines on certain expense items; – Need to implement dedicated company policies for travel management; – Adoption of more rigorous internal procedures for verifying and storing traceable payment receipts. The Tax Authorities should provide further clarification to deal with ambiguous situations or those not covered by current legislation. In the meantime, companies are advised to update their procedures and adequately train the staff responsible for administrative management. The traceability of payments is not only a tax obligation but also an essential condition for ensuring the correct deduction of expenses and avoiding unexpected tax burdens, both for the company and its employees. Date of publication Author Areas of activity Assistenza Fiscale (4)