Legislative Decree no. 148 of 7 August 2026 (the “Omnibus Decree”), in force from 12 August 2026, introduces a broad package of fiscal changes. Topics range from the biennial preventive agreement (CPB) and the 2020-2023 tax amnesty to company car fringe benefits, VAT deduction deadlines, and POS-receipt misalignment penalties. Below are the most operationally significant measures.
Tax dependants: new rules retroactive from tax year 2025
The criteria for qualifying as a “family member” under Article 12 of the TUIR have been redefined. For spouses (not legally and effectively separated) and children, the qualification no longer depends on cohabitation or the receipt of maintenance payments. For other relatives listed in Article 433 of the Civil Code, however, cohabitation or maintenance receipt remains a requirement when tax provisions specifically demand the status of “fiscally dependent family member.” These rules apply retroactively from tax year 2025, directly affecting the 730/2026 and REDDITI PF 2026 returns.
Company car fringe benefits: new rates from 2026
From tax year 2026, the fringe benefit on vehicles made available for mixed personal and business use is no longer based on CO₂ emissions. Instead, the general rule is 50% of the conventional ACI cost for 15,000 km. This falls to 10% for purely battery-electric vehicles and to 20% for plug-in hybrids. Moreover, the value increases by 50% after the fifth year from first registration, and by 5% for optional extras not listed in ACI tables. For vehicles covered by contracts signed between 1 July 2020 and 31 December 2024, or ordered by 31 December 2024 and made available by 31 December 2025, the previous CO₂-based rules continue to apply, including the same 50% and 5% uplifts.
Tax credit differentials: 26% substitute tax for self-employed professionals
Positive differentials arising from the sale or offsetting of tax credits — including construction bonuses — now constitute self-employment income. They are subject to a 26% substitute tax. This applies to credits purchased from 12 August 2026. Nevertheless, professionals may opt to apply the new rules also to credits purchased from the tax period running at 31 December 2024, by filing an amended return. Credits arising from tax liquidation and those received as consideration for professional services are excluded.
VAT: two-year deduction window restored and year-end invoice rule clarified
The two-year window for exercising the right to deduct VAT — which predated the changes introduced by Decree-Law 50/2017 — has been reinstated. The deduction may be exercised at the latest with the return for the second year following the one in which the right arose. Similarly, purchase invoices must be registered before the periodic settlement in which the deduction is claimed, and in any event within the filing deadline for the annual return for the second year following receipt. In addition, the amendment should allow retroactive deduction for so-called “year-end invoices,” at least within the annual return for the year the tax became due.
CPB 2026-2027: revised exclusions, forfeiture rules and ISA rewards
The Omnibus Decree significantly amends the biennial preventive agreement (CPB) framework, with effect from the 2026-2027 cycle. Opting in without meeting the access requirements no longer triggers forfeiture — the adhesion is simply void. Furthermore, filing an amended REDDITI return no longer constitutes a forfeiture event, provided corrections do not alter the agreed income or net production value by more than 30%; if they do, however, forfeiture applies. For professionals participating in professional associations or STP entities, the joint-adhesion rule only operates where the individual’s and the collective entity’s activities fall under the same ISA. Those renewing the CPB benefit from higher compliance-mark exemption thresholds — €70,000 for direct taxes and IRAP, €100,000 for VAT — and an advancement of 2 years in the assessment limitation period.
2020-2023 tax amnesty: available to ISA taxpayers renewing CPB by 31 October 2026
ISA taxpayers who renew their CPB adhesion for the 2026-2027 cycle by 31 October 2026 may access the voluntary disclosure regime for tax years 2020, 2021, 2022 and 2023. This is reserved exclusively for those renewing the CPB, not for first-time applicants. Payment of the substitute tax — with a minimum of €1,000 per year — is due by 15 March 2027, either in a single payment or in up to 10 monthly instalments. Both the rate and the taxable base depend on the taxpayer’s ISA reliability score and the specific year in question. Opting in protects those years from income adjustments by the Tax Authority.
POS-receipt misalignments: 5% tolerance threshold introduced
In line with the POS-cash register connection rules, the Omnibus Decree introduces a non-punishability threshold. The penalty of €100 per incorrect transmission, capped at €1,000 per quarter, does not apply where the discrepancy between electronic payments accepted and those recorded in the daily receipt data does not exceed 5%. The same threshold applies to the ancillary penalty of licence suspension for more than four violations within five years. Given the principle of favor rei, the non-punishability provision should apply retroactively.
Further changes at a glance
Several further changes deserve attention. For agricultural businesses, coordination rules align income taxation with the reform under Legislative Decree 192/2024. The deductibility of bond impairments in current assets is now aligned with the applicable accounting principles, removing the previously criticised minimum-value cap. For IAS/IFRS entities, deduction rules for trademarks, goodwill and indefinite-life intangibles are rationalised at a maximum of 1/18 of value per year; stock option plan costs and industrial holding classification rules are also updated. Close-company profit distribution presumptions are codified for the first time. The withholding tax on dividends paid to European pension funds rises from 11% to 20%. For Third Sector entities (ETS), IRAP qualification is determined under TUIR rules, avoiding potential cost deductibility issues for social and health-care bodies.
To assess how these provisions apply to your situation, contact Studio RCG.