Decree-Law no. 38 of 27 March 2026 (the so-called “Fiscal Decree”) was converted into Law no. 88 of 22 May 2026, in force from 23 May 2026. The conversion introduced significant amendments across several areas: the biennial preventive agreement (concordato preventivo biennale), the rottamazione-quinquies instalment relief, tax credits for agricultural businesses, and the threshold for blocking professional payments by public bodies. Below are the most operationally relevant changes for businesses and professionals.
Biennial Preventive Agreement (CPB) 2026–2027: deadline 31 October 2026
The deadline to opt into the CPB 2026–2027 is 31 October 2026, aligned with the submission deadline for the 2026 REDDITI income tax return. Since 31 October falls on a Saturday, the return deadline shifts to 2 November 2026. A corresponding extension for CPB adhesion is expected but awaits confirmation from the Italian Tax Authority (Agenzia delle Entrate).
Among the amendments introduced by the conversion law: the hyper-depreciation benefit (investments made between 1 January 2026 and 30 September 2028) is excluded from the CPB proposal calculation. New caps on proposed income increments apply to taxpayers with low ISA reliability scores: maximum 30% for scores between 6 and 8, maximum 35% for scores below 6.
Rottamazione-quinquies extended to regional and local authorities
The rottamazione-quinquies instalment relief now covers debts — both tax and non-tax — assigned to collection agents between 1 January 2000 and 31 December 2023 by Regions and local authorities. Creditor entities must adopt a resolution and notify the collection agent by 30 June 2026. From 15 September 2026, debtors can view their eligible balances in the reserved area of the Agenzia delle Entrate-Riscossione website.
Applications must be submitted electronically between 16 September and 31 October 2026. Payment may be made in a single instalment by 31 January 2027, or in 54 bimonthly instalments (minimum €100.00 each) through 2035, with interest at 3% per annum. For non-tax administrative penalties (including road traffic fines), only interest and accessory charges are waived; the principal penalty remains due.
Fuel tax credit for agricultural businesses
Agricultural businesses are entitled to a tax credit of up to 20% of fuel costs incurred in March, April and May 2026, as documented by purchase invoices net of VAT. The overall budget cap is €90 million for 2026. The credit must be used exclusively via offsetting in the F24 form by 31 December 2026. It is fiscally neutral for income tax and IRAP purposes, and may be combined with other incentives covering the same costs, provided the total relief does not exceed the actual expense incurred. Implementation criteria will be set by ministerial decree.
Threshold for blocking public authority payments to professionals: €5,000
From 15 June 2026, the mechanism blocking payments by public bodies to professionals and artists is triggered only where outstanding payment notices total at least €5,000.00. Below this threshold, fees are paid without any preliminary check for outstanding tax debts. The amendment applies also to fees for past professional services, provided they are settled from 15 June 2026 onwards.
Seafarers on foreign-flagged vessels: IRPEF exemption
Italian-resident seafarers who serve for more than 183 days within a 12-month period on non-EU/EEA flagged vessels engaged in international commercial traffic are now exempt from IRPEF (personal income tax) on their employment income. The previous regime of notional wages (retribuzioni convenzionali) no longer applies to this category. Exempt income remains relevant, however, for the calculation of deductions, tax credits and means-tested social benefits.
Transition 5.0: grant for renewable energy self-production plants
Businesses that received GSE confirmation of technical eligibility under the Transizione 5.0 tax credit but were excluded due to exhaustion of available funds may access a dedicated grant for investments in renewable energy self-production plants. The grant is fiscally neutral (excluded from taxable income and IRAP base) and cannot exceed the tax credit applied for in respect of the same expenditure. Funding allocated: €57.7 million for 2026, €80 million for 2027 and €60 million for 2028. Operational procedures will be established by the Ministry of Enterprises and Made in Italy (MIMIT).
Further amendments at a glance
The decree also covers other areas. Travel agencies regain the withholding tax exemption on commissions relating to passenger transport ticketing. For barter transactions and payments in kind, VAT is now calculated on the monetary value as determined by the contract (subject to a floor equal to total costs). Businesses adversely affected by energy cost increases linked to the Persian Gulf conflict may apply for non-repayable grants of up to 20% (30% for SMEs) under the Fondo 394, with applications open until 31 December 2026. A new Fund for craft enterprises is established, endowed with €20 million in 2027 and €30 million in 2028, to support access to credit.
To assess how these provisions affect your specific situation and receive support with compliance, contact Studio RCG.