Further to Tax Newsletter no. 5 – August 2026, which set out the measures of greatest operational significance introduced by Legislative Decree no. 148 of 7.8.2026 (published in the Official Gazette of 11.8.2026 no. 185, Ordinary Supplement no. 30, in force since 12.8.2026), the fourth corrective decree implementing the tax reform, we enclose a summary table of the measures discussed therein, together with their respective effective dates.
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Measure |
Effective date |
Business income |
|
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Fringe benefit on company cars for mixed use and optional equipment |
From 2026, with the transitional regime under Art. 1(48-bis) of Law 207/2024 also rewritten and conduct adopted up to 31.12.2025 preserved. |
|
Gains on the assignment or offsetting of tax credits |
Credits purchased from 12.8.2026, with the option of early application from the tax period in progress at 31.12.2024 (amended return, no refund). |
|
Deductibility of stock option plan costs |
Transactions resolved upon from the tax period following the one in progress at 31.12.2025. |
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Amortisation of trademarks, goodwill and indefinite-life intangibles – IAS/IFRS adopters |
Assets recognised, or higher values acknowledged, from 2026. |
|
Grants against research and study costs |
Grants obtained from 2026. |
|
Entities treated as industrial holding companies |
From the tax period following the one in progress at 31.12.2025. |
|
Carry-forward of business losses |
Provision of authentic interpretation: it is also relevant for the past, broadening the scope of Art. 84(3) of the ITC. |
|
“Pre-merger” tax period and carried-forward surpluses |
From 12.8.2026, the date on which Legislative Decree 148/2026 entered into force. |
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Contributions in kind of shareholdings at a loss |
Contributions made from 2026, with effects also on prior periods from 31.12.2024 where the returns filed are consistent. |
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Certified date for the permanent establishment’s financial report |
From the tax period in progress at 31.12.2026. |
|
Carry-forward of final foreign losses |
From 12.8.2026, the date on which Legislative Decree 148/2026 entered into force. |
VAT |
|
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VAT deduction and recording of invoices |
Mirroring amendments to Arts. 56 and 88 of the new VAT Consolidated Act, applicable from 1.1.2027. |
Tax assessment, penalties and collection |
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Presumed distribution of off-book profits |
No express transitional rule is provided: an aspect to be monitored in respect of pending proceedings. |
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Assessment of multi-year deductible items |
Goods and services purchased from the tax period in progress at 31.12.2027; no effect on pending proceedings. |
|
Mismatches between POS data and electronically transmitted considerations |
The ground for non-punishability should apply retroactively pursuant to Art. 3(2) of Legislative Decree 472/97. |