With the MEF Decree of 27 June 2025, published in implementation of Article 4, paragraph 7-quinquies, of Legislative Decree No. 38/2005, the coordination measures between the provisions of accounting standard OIC 34 on revenue recognition and the rules for determining the taxable base for IRES and IRAP have been defined. The decree applies to the financial statements of fiscal years beginning on 1 January 2024 and concerns entities other than micro-enterprises that do not prepare their financial statements in ordinary form and, pursuant to Article 83, paragraph 1, of the TUIR, adopt the strengthened derivation principle.
Regulated cases
- Costs for obtaining the contract (art. 2)
- Contractual penalties (art. 3)
- Sales with right of return (art. 4)
Areas not expressly regulated
For any aspects not specifically covered by the decree, fiscal relevance follows the accounting criteria of OIC 34, in particular:
- identification of the accounting units
- contract grouping
- determination of the total contract price (including discounting of cash flows beyond 12 months)
- criteria for recognizing revenue by entities acting as agents
- criteria for timing of revenue recognition
Sale of goods
Revenue is recognized at the transfer of the substantial risks and rewards, provided the amount can be determined reliably.
Provision of services
Revenue is recognized based on the stage of completion when the right to payment and the amount are reliably measurable; otherwise, it is recognized upon completion of the performance.
By virtue of the strengthened derivation principle, these criteria for revenue qualification and timing take direct fiscal relevance.
If you need further clarification on this matter, feel free to contact us.