The 2026 Budget Law (L. 199/2025, art. 1 paragraphs 82-100) introduced the Rottamazione-quinquies (fifth tax settlement), allowing settlement of debts delivered to the Revenue Collection Agency from January 1, 2000 to December 31, 2023. Unlike previous settlements, this has a narrower scope: it only covers debts from automatic settlement and formal control of tax returns (income, VAT, IRAP, withholding agent), declared but unpaid INPS contributions (excluding those from assessments), and penalties for traffic code violations imposed by state administrations. Applications must be submitted by April 30, 2026 via the Revenue Collection Agency portal, with payment (or first installment) due by July 31, 2026.
What is included and excluded
Settleable are rolls resulting from unpaid declared taxes, undue deductions or exemptions without supporting documentation, deducted withholdings without substitute’s certification, credits offset beyond legal limits. Also included are rolls from periodic VAT settlement cross-checks and those from lapse of friendly notice installment plans. Not included are debts from professional pension funds (accountants, lawyers), ENASARCO, local entities (IMU) and those from assessment, liquidation or tax credit recovery notices. Taxpayers can selectively choose which debts to settle, even within the same payment notice.
Benefits and amounts due
Settlement automatically cancels administrative penalties, interest included in charges (including late enrollment interest), default interest and collection fees still due. Principal amounts (taxes, contributions) and execution and notice expenses must be paid in full. For state traffic penalties, cancellation covers only fees, interest and surcharges. Those who lapsed from previous settlements (2016-2019 and settle and cancel) can access the new settlement, provided eligible charges. Those who lapsed from fourth settlement after September 30, 2025 cannot benefit.
Payment methods and installments
Payment can be made in single solution by July 31, 2026 or installments up to 54 bimonthly payments, from July 2026 to May 2035. Deferred amounts accrue 3% annual interest from August 1, 2026. The Revenue Collection Agency communicates amount settlement with payment plan by June 30, 2026. Payment possible via precompiled payment slips, direct debit, Agency offices, home banking or other channels like payment points and CBILL. Offset is excluded.
Application effects and lapse
Once application submitted, Agency cannot initiate new enforcement actions or impose administrative freezes and mortgages (existing ones remain). Debtor considered compliant: PA payment block doesn’t apply, DURC obtainable, F24 offset possible. Any garnishments cannot be initiated or continued (except positive first auction) and extinguish upon first installment payment. Previous installment plans suspended until July 31, 2026 then automatically revoked. Lapse from settlement occurs for omitted or insufficient payment of total amounts, two installments even non-consecutive, or last installment, with no tolerance for delays. Lapse is automatic and original debt reemerges including penalties, interest and fees.
Litigation and preliminary checks
Pending litigation doesn’t prevent settlement, but application must include commitment to waive ongoing proceedings. Application with receipt submitted to Tax Court suspends process. If first installment or full amount paid by July 31, 2026, process extinguishes with compensated costs; otherwise resumes normally. To preliminarily verify settleable charges, access reserved area of Revenue Collection Agency website with SPID or request statement via public area. Application must be submitted exclusively via electronic application, even without digital identity, or from reserved EquiPro area for authorized intermediaries.
Studio RCG is available to verify settleable charges and assist in fifth settlement application submission by April 30, 2026.