Law December 2, 2025, No. 182, published in the Official Gazette on December 3, 2025 and effective from December 18, 2025, introduces numerous simplification and digitalization measures in tax, labor, real estate and administrative matters.
Depreciation suspension extended to 2024 financial statements
Companies preparing financial statements according to the civil code can suspend depreciation of tangible and intangible fixed assets also for financial statements relating to the fiscal year ending December 31, 2024. The suspension requires allocation of profits to an unavailable reserve and appropriate disclosure in the Notes. From a tax perspective, deduction remains permitted for both IRES and IRAP purposes, regardless of income statement allocation. The rule presents criticalities for companies with calendar-year fiscal periods whose 2024 financial statements have already been approved.
Photovoltaic incentives and Tremonti environmental: new procedure
For SMEs that benefited from Tremonti environmental tax relief and GSE energy incentives, a new settlement procedure is introduced. By February 16, 2026, taxpayers can submit an application to GSE accepting compensation of the tax benefit received and a 5% reduction of incentive tariffs for the entire agreement period. The procedure affects all pending tax and administrative proceedings.
Electronic invoices for agricultural supply chains: identification code
From March 18, 2026, electronic invoices for transfers of products covered by National Single Commissions must include an identification code to ensure transparency in supply chain commercial relations. The Revenue Agency will issue implementing provisions by that date. The provision is effective until December 31, 2026.
Repeal of receipts transmission via advanced payment systems
The regulation providing for receipt transmission via advanced payment systems (credit cards and electronic payments), never implemented due to operational complexity, is repealed. Compliance will be managed through new software solutions installable on smart-POS, PCs, smartphones and tablets, simpler from a technical standpoint.
Simplifications for foreign workers’ employment
The law introduces facilitative measures for entry of foreign citizens for work purposes. Among the innovations: simplified requirements for worker accommodation, reduction from 60 to 30 days of timeframes for work authorization issuance, and streamlined procedures for hiring highly qualified workers. Employer organizations and labor consultants can now verify requirements also through territorial structures.
Social safety nets: new communication obligations
Workers receiving CIGO or CIGS benefits who perform other work activities must now communicate this circumstance not only to INPS but also to the employer benefiting from wage integration, immediately after starting the activity.
Occasional agricultural work extended to 2025
The fixed-term occasional agricultural work contract (LOAgri) is extended until December 31, 2025. Seasonal agricultural services may last maximum 45 days per year per worker, with contracts of maximum 12 months duration.
Real estate donations: new restitution rules
The discipline of restitution action for donated properties changes. Prejudiced forced heirs can no longer request restitution from third-party purchasers of the donee, but only from the donee itself or receive monetary compensation. New rules apply to successions opened after December 18, 2025. For previous successions, a transitional regime is provided with deadline June 18, 2026 to notify and register opposition to donation.
Registration of tacit and presumed inheritance acceptance
It is now possible to register in public records inheritance acceptance even when occurring tacitly or through possession of hereditary assets, through substitute declaration of notoriety act in the form of public deed or authenticated private deed.
Halved timeframes for absence and presumed death declarations
Timeframes for absence declaration are reduced from two years to one year, while those for presumed death declaration decrease from ten to five years from the last news of the missing person.
Building permit with tacit consent for protected properties
For properties subject to hydrogeological, environmental, landscape or cultural constraints, the possibility of tacit consent on building permits is introduced if all authorization provisions relating to constraints have already been acquired and are currently valid.
Tourism staff houses: simplified procedures
Renovation works on staff houses for tourism-hospitality sector workers, if started by December 31, 2026, can be carried out with SCIA instead of building permit. A ten-year use destination constraint and obligation to stipulate agreements with parking managers are provided.
Single fee: exemption extended to signs and construction sites
Exemption from the single property fee is extended to business signs (in addition to already exempt shop signs) and construction sites (in addition to premises), provided they are up to 5 square meters in size.
Amusement parks excluded from ticket nominativity
Amusement parks are excluded from the obligation to issue nominative access tickets provided for facilities with capacity exceeding 5,000 spectators, within the anti-secondary ticketing discipline.
Studio RCG remains available to explore specific aspects of each innovation and assess the impact on individual business realities and personal situations.