Bonus for returnees to Italy: double stop to cumulation arrives

A double squeeze is coming on facilitated regimes for those returning to Italy. In the crosshairs come the cumulation possibilities still present in the folds of the regulations after the reform of impatriates (50% tax relief that can rise in some cases to 60% to attract talent and brains from abroad) arrived with one of the implementing decrees of the tax delegation (Legislative Decree 209/2023). Hence, the hypothesis of disproportionately increasing the tax advantage by adding together access to the regime reserved for new entries and returns with that of teachers and researchers. But there will also be a barrier between impatriates and the so-called Paperoni's regime, which provides for a substitute tax (100,000 euro raised to 200,000 for those who entered Italy after the Omnibus Decree modifications) only, however, in this case for income produced abroad. With a preclusion destined to be triggered as early as the 2024 tax year. This is one of the novelties contained in the tax decree expected today, Thursday 12 June, in the Council of Ministers.

A decree that could be split into two parts with respect to the other emergency measure that also contains, among other things, the extension of the entry into force on 1 January of the sugar tax so that it will not be triggered by 1 July and the long-awaited lowering of VAT to 5% on the sale of works of art in order to put Italy on a par with its other European partners. Measures that, however, unlike those in the 'only' tax decree, require coverage.

Also for this reason, despite appearing in the first drafts circulated with a date still blank, it will be necessary to wait for the final technical and political assessment on the hypothesis of postponing the deadline for the payment of income tax, VAT and IRAP due on the basis of the 2025 declarations by VAT numbers for which the tax reports are (or could be) applied. The hypothesis on which the technicians' reasoning continued yesterday is that of setting the deadline on 15 or 20 July.

Complicating the hypothesis is the obvious reason of safeguarding the cash flows needed to pay civil servants' salaries and pensions. Not least because the extra time would have a wide-ranging scope since it would affect 4.6 million VAT regimes, including both those adopting the flat tax (flat-rate and ex-minimum) and those participating in companies, associations and enterprises. And it would then be necessary to establish how far the possibility of paying with the 0.40 per cent surcharge would go.

But also under scrutiny are other changes to the tax calendar. Highly anticipated by globalised companies that operate in several countries and that take advantage of individual national rules to deduct costs or obtain tax advantages in several countries. The deadline for the dossier to neutralise possible future penalties by the tax authorities for tax periods from 2020 to 2022 is 30 June. The decree aims to align the current end-of-June deadline with the 31 October deadline for documentation for tax periods 2023 and 2024.