Legislative Decree December 18, 2025, No. 192, published in the Official Gazette on December 19, 2025 and effective from December 20, 2025, introduces numerous corrective and supplementary amendments to legislative decrees implementing tax reform. Below, we will describe the main changes relating to personal income tax, business income, international taxation and tax assessment.
Dependent family members: extended safeguard clause
The safeguard clause for applying other tax provisions (deductions, expense deductions, corporate welfare) is extended to all family members who previously entitled to deductions, not just children. Family members are considered dependent, even if deduction no longer applies, including non-separated spouse, children and other subjects under art. 433 Civil Code (parents, grandparents, siblings, in-laws) cohabiting or receiving alimony, with income not exceeding 4,000 euros (children up to 24 years) or 2,840.51 euros (others). The amendment has retroactive effect from January 1, 2025.
Pension contribution waiver: extended exemption
The facilitated tax regime for salary portions from waiver of pension contribution credit is extended to exclusive forms of Mandatory General Insurance (previously limited to substitute forms). Salary portions from waiver for the period after first retirement eligibility deadline do not constitute income. Applicable to income received from 2025 tax period.
Accounting error corrections: revised discipline
The discipline on tax relevance of accounting error corrections is significantly limited. Tax relevance is now recognized only for non-material errors (according to accounting principles) made by entities mandatorily subjecting financial statements to legal audit. For material errors, supplementary declaration remains necessary. Correction must occur before approval of following year’s financial statements or before start of inspections and verifications. New discipline applies to corrections in financial statements starting from 1.1.2025.
Strengthened derivation for micro enterprises
The strengthened derivation principle applies to micro enterprises choosing to prepare financial statements in ordinary or abbreviated form (previously only ordinary). Application is confirmed also for investment entities and financial holding companies that cannot benefit from micro enterprise simplifications. Applicable from 2025 tax period.
Value realignment: also between entities with same principles
The regime for realigning differences between accounting and tax values in neutral extraordinary transactions (merger, demerger, contribution) now applies also to transactions between entities adopting the same accounting principles, if modification of qualification, classification and temporal allocation criteria occurs. From 2025 tax period.
Shareholding contribution: authentic interpretation
For contribution of qualified shareholdings in holding companies with controlled realization, an authentic interpretation rule (effective from 31.12.2024) clarifies that the prevalence test is based on net equity accounting value and not shareholding accounting value. The prevalence condition exists when total net equity accounting value of participated companies exceeding thresholds represents more than half of the total.
Spin-off demergers: neutrality for pre-existing beneficiaries
Tax neutrality for spin-off demergers also applies to pre-existing beneficiaries. In spin-off of permanent establishments of EU/EEA companies, shareholding assignment to demerging company does not trigger taxation even if not connected to an Italian permanent establishment. Applicable to demergers from 2024 tax period.
Conventions with Russia and Belarus: reciprocal suspension
If a foreign jurisdiction unilaterally suspends a Double Taxation Convention, Italy suspends the same provisions as countermeasure. For Russia and Belarus, outflows from Italy are subject to withholding at full rates (not conventional). Double taxation is eliminated through foreign tax credit until 2028. Possible to file supplementary declarations to recover foreign taxes paid in excess, without penalties and interest.
Rulings: regulatory coordination
Ruling discipline is reorganized with updated regulatory references. Probative ruling is now regulated by art. 11 para. 1 letter e) of L. 212/2000. Contribution obligation for filing “particularly complex” ruling requests is introduced, with amount based on turnover and ruling type. Details will be defined by ministerial regulation.
Cooperative compliance: certification extension
Taxpayers who filed cooperative compliance applications in 2024 and 2025 are admitted even without tax risk control system certification, which must be submitted by September 30, 2026. Failure to submit constitutes exclusion cause.
Other relevant innovations
The 60-day term for preventive adversarial procedure is unified for both counter-arguments and document access requests. Mandatory self-assessment is extended to sanctioning acts. Private entities can no longer request legal consultation. Regarding customs, confiscation is excluded if customs duties, interest, penalties and management expenses are paid. For excise duties, those purchasing natural gas in cylinders from national suppliers are included among obligated parties.
For detailed analysis of all amendments, consult Studio RCG’s complete circular. The firm is available to explore specific aspects of each innovation and assess the impact on your situation.