The Decree-Law 84/2025, published on June 17, 2025, has corrected and integrated the provisions introduced by the 2025 Budget Law (L. 207/2024), resolving the issues of regulatory coordination that had emerged with the amendment of Article 54 of the TUIR by Legislative Decree 192/2024.
Among the main interventions, first of all, paragraph 81, letter b) of the 2025 Budget Law (L. 207/2024) has been eliminated. This paragraph had introduced the obligation of traceability for expenses such as meals, accommodation, travel, and transportation, but referred to an outdated version of Article 54 of the TUIR, creating interpretative confusion.
To remedy this, Decree-Law 84/2025 has reintroduced the obligation of traceability in a more coherent and updated manner, inserting a new paragraph 2-bis in Article 54 of the TUIR. According to this provision, the expenses referred to in paragraph 2, letter b) of Article 54 of the TUIR incurred by professionals cannot be deducted or excluded from taxable income unless they are paid with traceable instruments, such as bank transfers, payment cards, or apps linked to a bank account.
In particular, paragraph 2, letter b) of Article 54 of the TUIR states that “the sums received as reimbursement for expenses incurred by the holder of an art or profession for the execution of an assignment and charged analytically to the client do not contribute to forming the income.”
In this regard, the regulation provides that in the event of non-fulfillment by the client, meaning if the expenses are not reimbursed, they can be deducted by the party incurring them provided that the payments have been made using the aforementioned payment systems.
Decree-Law 84/2025 also intervenes on the regulation of travel expenses by inserting the new paragraph 6-bis within Article 54-septies of the TUIR, which states that:
- Expenses related to meals, accommodation, travel, and transport via taxi or NCC directly incurred by the client;
- Expenses related to meals, accommodation, travel, and transport via taxi or NCC directly incurred by the client for assignments given to other self-employed workers;
- Expenses analytically reimbursed to employees for travel or to other self-employed workers for the execution of assignments;
are deductible from the income of the individual exercising arts and professions only if the payment is made using traceable payment systems.
Furthermore, as clarified by Article 1 paragraph 1 letters c) and e) of Decree-Law 84/2025, the obligation of traceability applies only to meal and accommodation expenses incurred in Italy. Expenses incurred abroad, on the other hand, are excluded from this obligation, unless they are representation expenses, which remain subject to traceability even if incurred outside the national territory.
Therefore, for example, expenses for taxis incurred during a trip abroad can be paid in cash.
With particular reference to representation expenses, paragraph 2 of Article 54-septies of the TUIR has been amended to state that “they are deductible up to 1 percent of the fees received in the tax period if the payments are made through bank or postal payments or by other payment systems provided for in Article 23 of Legislative Decree 9 July 1997, n. 241.”
The new traceability obligations also apply for the determination of the IRAP taxable base. The provisions concerning representation expenses and expenses related to meals, accommodation, travel, and transportation via taxi or NCC directly incurred by the client in their activity will be applicable from June 18, 2025. The other amendments are applicable from the tax period in progress at the date of publication of Decree-Law 84/2025, thus from the fiscal year 2025.
