Budget Bill, ABI: tax measures totalling 22 billion to be introduced for banks from 2025. “A fundamental rethink is needed”
This should be ‘accompanied by a proper assessment of the cumulative effects and of the possible compatibility with constitutional law and with the European regulations to which the banks are subject, as will be set out in the final opinions of the law firms’
The ABI “stresses the importance of assessing, in conjunction with this budget bill currently under consideration, the fiscal measures adopted in the 2025 and 2026 budget laws, which have an impact of 22 billion euros”. This was stated by the association’s Director-General, Marco Elio Rottigni, during a parliamentary hearing on the budget. Rottigni calls for ‘avoiding excessive penalties on costs necessary for operations and investments, in order to safeguard the certainty of the rules applicable to loans and tax matters, whilst also avoiding distortions of competition’ within the EU. The ABI ‘strongly supports the need to identify improvements’ to the measures.
The 2027 Budget Law ‘provides for measures that will affect banks’ profitability, liquidity and, in some cases, regulatory capital, resulting in a further increase in revenue for the State of approximately a further 7 billion euros over the next three years’. The hearing referred to the further increase in the IRES surcharge and the proposal for a structural restriction on IRAP deductions (4.8 billion), as well as deferrals of deductions and offsets (2.1 billion), which also have an impact on prudential supervisory ratios,
A fundamental rethink is needed
What is being called for is a fundamental re-evaluation of the proposed provisions in order to establish a proportionate and predictable legal framework. According to Director-General Rottigni, this should be ‘accompanied by a proper assessment of the cumulative effects and potential issues of compatibility with constitutional law and the European regulations to which banks are subject, as will be set out in the final opinions of the law firms’.
Superbonus tax credits: conflict with Constitutional Court rulings
The provision in the Budget Law that amends ‘the timing of tax credit offsets arising from notifications of transfer or discount for Superbonus schemes’ is ‘at odds with the ruling of the Constitutional Court, which considers it unlawful to affect the economic calculations of businesses on a “now for then” basis’.
Rottigni points out that ‘the amount available for use in 2027 would be spread over ten annual instalments. The measure would apply to receivables acquired on the basis of a utilisation schedule already defined by law and would alter their economic and financial values; consequently, it would amount to a forced restructuring of government debt’. For the banks, “this would result in significant negative effects on their profit and loss accounts, balance sheets and liquidity, coupled with an additional cost linked to inflation”.

