With the Legislative Decree 81 of June 12, 2025, in force from June 13, 2025, significant changes have been introduced in the areas of tax compliance, assessments, litigation, and penalties. Below, we highlight the main changes of operational interest for businesses, professionals, and taxpayers.
1. Flat-Rate Tax Regime – Profitability Coefficients
In the 2025 Income Tax return (REDDITI PF 2025), flat-rate taxpayers must indicate both the ATECO 2025 and ATECO 2007 codes to correctly determine the profitability coefficient.
2. VAT for Flat-Rate Taxpayers – Reverse Charge
Flat-rate taxpayers can now pay VAT on reverse charge purchases quarterly. This applies to purchases from both EU and non-EU suppliers.
3. Single Certification – New Deadlines
Starting in 2026, Single Certifications related to habitual self-employment and commissions must be transmitted to the Revenue Agency by April 30.
4. Pre-filled Tax Return – Delay in Availability
Starting in 2026, the pre-filled tax return will be available:
- by May 20 for self-employed individuals and other income not from employment;
- remains April 30 for employees and assimilated individuals.
5. Healthcare Services – Permanent Ban on E-Invoicing via SdI
The permanent ban on e-invoicing via SdI for healthcare services to individuals is now official. Other channels (analog or extra-SdI) must be used.
6. Health Care System – Annual Data Submission
Starting in 2025, healthcare expenses must be reported to the Health Care System annually, not semi-annually.
7. Receipts – Electric Vehicle Charging
Specific rules have been introduced for operators offering electric vehicle charging services. A subsequent decree from the Revenue Agency will define the rules and timelines.
8. Assessment with Agreement – New Rules
It will no longer be possible to submit a second application for agreement in certain cases already addressed. The changes also apply to indirect taxes such as registration tax and inheritance tax.
9. State Aid – New Deadlines for Recovery
The Revenue Agency can issue assessments for undue state aid up to 8 years from the receipt or violation.
10. Suspension of Deadlines – Abolished by December 31, 2025
The 85-day extension of deadlines due to the Covid emergency is eliminated. Pay attention to the affected years (e.g., omitted income for 2017–2018).
11. Appeal and Self-Protection – Extended to Pending Cases
The possibility to settle disputes with reduced penalties will also apply to ongoing cases, not just violations from September 1, 2024 onwards.
12. Conciliation in Cassation – Extended to All Appeals
The possibility of out-of-court conciliation is extended to all cases pending before the Court of Cassation, even those initiated before January 5, 2024.
13. Tax Process – Document Conformity Certification
Starting from September 2, 2024, it will be mandatory to certify the conformity of scanned documents submitted in the telematic tax process.
14. Registration Tax – Minimum Penalty Reintroduced
A minimum penalty for omitted (250 euros) or delayed registration (150 euros) of acts is reintroduced.
15. Customs Duties – New Penalty Thresholds
The threshold for criminal penalties related to violations other than customs duties increases to 100,000 euros. Changes are also introduced regarding self-correction and administrative confiscation.
For more details on the changes that directly affect your situation, we invite you to contact RCG Studio for personalized advice..