Late filing of tax returns: reduced penalties if action is taken before audits
Recent legislative developments provide broader opportunities to remedy a failure to file a tax return before the start of tax audits. In particular, if the return is submitted within the statutory assessment deadlines, reduced penalties apply compared to the ordinary ones. This benefit also applies beyond 90 days from the original deadline, as provided for by Articles 1 and 5 of Legislative Decree no. 471/1997.
A separate case arises, however, when the omission has criminal relevance: in this situation, pursuant to Article 13 of Legislative Decree no. 74/2000, non-punishability is conditional not only on the filing of the return within the following year, but also on the full payment of taxes, interest, and penalties. Timely management is therefore crucial.
VAT credit notes: key deadline of 30 April
With the filing of the 2025 VAT return by 30 April 2026, the time window for issuing VAT credit notes (downward adjustment notes) relating to events that occurred in 2025 also comes to an end. Article 26 of Presidential Decree no. 633/1972 links the issuance of such documents to the moment when the right to deduct VAT arises, which is governed by Article 19 of the same decree.
It is therefore essential to correctly identify the dies a quo, which varies depending on the specific circumstance (e.g. insolvency proceedings, contract termination, court rulings). An incorrect assessment may prevent the recovery of VAT, making it necessary to resort to alternative instruments such as a refund. Timely review of open positions is therefore crucial.
Public grants: transparency requirements tied to the financial statements
The deadline for approving the 2025 financial statements also marks the cut-off for complying with transparency obligations regarding public grants received. Article 1, paragraphs 125 et seq., of Law no. 124/2017 requires companies registered with the Companies Register to disclose, in the notes to the financial statements, any contributions, subsidies, and economic advantages received from Public Administrations. This framework has recently been confirmed by the “Incentives Code” (Article 22 of Legislative Decree no. 184/2025).
For entities preparing abridged financial statements, it remains possible, as an alternative, to publish the required information on the company’s website by 30 June. The obligation does not apply if the total amount of grants received does not exceed €10,000 per year, and it is excluded for State aid and de minimis aid recorded in the National Register of State Aid. Accurate disclosure is essential to avoid penalties.
Dismantling and remediation: accounting treatments to be carefully distinguished
In accounting for environmental obligations, it is essential to distinguish between dismantling costs and remediation obligations. According to the clarifications provided by the Italian Accounting Standard setter (OIC), costs related to the removal of assets and the restoration of the site fall under OIC 31 and require the recognition of a provision, with a corresponding increase in the carrying amount of the related asset.
By contrast, subsurface remediation costs are treated differently: they are recognised in the income statement when the environmental damage actually arises. A provision may be recognised only where there is a definite obligation and a reliable estimate of the future outflow, with discounting applied where appropriate. It is not permissible to accrue provisions for liabilities that are merely probable and not reliably measurable. Adequate disclosure in the notes to the financial statements, as required by OIC 31, therefore remains essential.
EU Inc.: a new gateway to the European single market
The European Commission has presented the draft regulation COM(2026) 321 to introduce the EU Inc., a new European private limited company designed to operate smoothly within the single market. This optional model, which will exist alongside national corporate forms, will apply the so‑called “28th regime”, based on rules harmonised at EU level.
Key simplifications include fully digital incorporation, the absence of a minimum share capital requirement, and automatic recognition across all Member States. The EU Inc. is mainly aimed at start‑ups, scale‑ups, and innovative SMEs interested in cross‑border operations. The goal is to reduce regulatory fragmentation and to foster investment and growth at the European level.
Small parcels: the €2 contribution postponed to summer
The application of the €2 contribution on low‑value imports has been postponed to 1 July 2026, instead of the originally planned 1 January date. The deferral was provided for by Article 5 of Decree‑Law no. 38/2026, currently undergoing parliamentary conversion, in order to allow the Italian Customs and Monopolies Agency to upgrade its IT systems.
The levy, introduced by paragraphs 126–128 of Article 1 of Law no. 199/2025, applies to shipments with a declared value not exceeding €150. The measure fits into a rapidly evolving European framework, marked by the reform of the Customs Union and the upcoming introduction of new EU‑level charges on low‑value consignments. The six‑month postponement may facilitate better alignment with future EU rules.
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