Foundation of Labour Consultant Studies

New rules for company cars and travel expenses: what changes in 2025

Insight into the new regulations of the Budget Law 2025. The manoeuvre has remodelled the taxable value according to the type of vehicle and its environmental impact. The aim is to incentivise the use of electric vehicles and plug-in hybrids, for which more favourable tax treatment has been envisaged

by Andrea Carli

Auto aziendali, Viano (Aniasa): data dell’ordine, non della consegna deve decidere il peso delle tasse

5' min read

5' min read

The easing of the tax squeeze on company cars, considered polluting, granted by an amendment of the rapporteurs to the Bills Bill, remains confined to the first half of this year. The proposed amendment, which was approved by the Productive Activities Committee of the Chamber of Deputies, excludes vehicles ordered in 2024 and to be deliveredby 30 June from the tax increase provided for in the last budget law. In the last few hours there had been speculation in majority circles that the Ministry of the Economy might 'open up' to the passing of this deadline, but a check on the costs involved resulted, we learn, in a negative response. The Bills Decree is expected in the House on Monday, 14 April when a request for a vote of confidence is expected. The measure, which expires on 29 April, will then go to the Senate for a second reading.

Before the last manoeuvre, the value of the fringe benefit on company cars, subject to taxation, was equal to a percentage of the kilometric cost that varied according to the vehicle's emissions. The taxable percentage went from 25 per cent of the kilometric cost (calculated on a mileage of 15,000 kilometres per year) for vehicles with CO2 emissions of less than 60g/km up to 50 per cent for vehicles with emissions of more than 190g/km. Instead, the new system introduced by the Budget Law distinguishes the taxation of the benefit according to the type of fuel, raising the taxable amount to 50% of the kilometric cost for all petrol and diesel vehicles regardless of emissions. The percentage drops to 20% for plug-in hybrids and 10% for electric vehicles.

Loading...

The new features introduced by the Budget Law 2025

.

And in the very same hours in which the parliamentary 'response' was formalised, and while waiting for the new salvage provided for by the Bollette decree to come into force, the Fondazione Studi Consulenti del Lavoro published an in-depth study entitled: 'Fringe benefit vehicles and traceability of travel expenses: what changes from this year', by Giuseppe Buscema and Michele Donati. More generally, in fact, as of 1 January 2025, with the entry into force of the Budget Law 2025 (Law 207/2024), the rules have changed on two fronts. The first is, precisely, that of company vehicles granted for mixed use. But there is a second strand that has seen changes, and that is that of expenses for board, lodging and transport for travel, which have become exempt from taxation only if paid by traceable means. Otherwise, these amounts will contribute to taxable income and will be non-deductible for the company.

Business cars: more favourable tax treatment for electric vehicles and plug-in hybrids

Let's start with company cars. As we wrote, the new rules remodel the taxable value according to the type of vehicle and its environmental impact. The aim is to incentivise the use of electric and plug-in hybrid vehicles, for which more favourable tax treatment is provided. In the document, the Study Foundation also highlights the impact on flat-rate allowances and the need for regulatory clarification in cases of vehicle registration and assignment between 2024 and 2025. "A first fact that emerges from the new wording of the rule," the document reads, "with a significant impact in terms of the tax due, is the increase in the values in kind deriving from the assignment for mixed use of vehicles that, although characterised by low emissions, no longer fall into the category of electric vehicles, or plug-in hybrids. The regulations applicable until 31 December 2024, in fact, tied the determination of the taxable income for IRPEF purposes of vehicles assigned to employees to carbon dioxide emission values'.

Previous rules applicable to vehicles registered and granted to employees as at 31 December 2024

According to the Study Foundation, 'the principle that provides for the possibility of applying the previous discipline to vehicles that as of 31 December 2024 were already registered and granted in mixed use to employees within the same terms must be considered implicitly operative'.

The three cases

.

In light of the changes triggered as of 1 January 2025, three cases are made. Thefirst is that relating to vehicles still in mixed use today for employees by virtue of assignments that occurred before 30 June 2020 (vehicles naturally registered before that date), for which the determination of the value must still be made today by assuming 30% of the conventional cost value determined for an average distance travelled of 15,000 km per year according to the ACI tables.

The second concerns vehicles registered and granted for multi-purpose use as from 1 July 2020, in respect of which an upward declination is introduced determined on the basis of emissions (25% of the value for vehicles with lower carbon dioxide emissions of less than 60 g/Km, 30% for vehicles with emissions between 60 g/Km and 160 g/Km, 50% - after 40% had been envisaged for the year 2020 only - for vehicles with emissions between 160 g/km and 190 g/km, and finally 60% - after 50% had been envisaged for the year 2020 only - for vehicles with emissions above 190 g/km) according to the ACI tables.

Finally, the third case concerns the declination contained in Article 51, paragraph 4, of the TUIR in force from 1 January 2025. It is worth recalling in this scenario, the technicians observe, 'how upon the expiry of an assignment agreement, or of the assignment of a different vehicle with respect to the one previously recognised, any new concession that is placed (both as a date of registration and - naturally - of assignment) from 1 January 2025 onwards, will be attracted to the new discipline resulting from the amendment of Law no. 207/2024'.

The complex case of registration and concession straddling the two periods

.

Then there is a rather complex case. "A case that is anything but rare and extremely delicate," the document continues, "takes shape in the hypothesis of asynchrony between the date of registration of the vehicle and the date on which the same vehicle is granted to the employee with respect to the discriminating date that concerns us; in other words, this scenario could currently materialise with respect to all those vehicles registered by 31 December 2024, but then actually assigned to the employee as of 1 January 2025.

Pre-2025 registration and post-1 January 2025 concession

With respect to the previous case (registration of the vehicle carried out by 31 December 2024 and actual concession after 1 January 2025) - the Study Foundation asks - is it possible to provide a different key of interpretation regarding the definition of the value that will constitute taxable income? "The only alternative that can in abstract be taken into consideration for some evaluations - the report explains - is the one that would lead to the discipline in force until 31 December 2024, and therefore to the relative formulation of Article 51, paragraph 4, letter a) of the TUIR. With respect to this thesis, it is possible to note the presence of an element that could lead to an affirmative answer, which, however, is counterbalanced by two more relevant considerations of an opposite sign. In support of this thesis could be the fact that the Legislator of the 2025 Budget Law has provided not only for the concession as from 1 January 2025, but also for the new registration'.

According to the labour consultants, 'it is desirable for the legislator to intervene in order to consider the provisions of Article 51, paragraph 4, of the TUIR also applicable in the case of vehicles registered by 31 December 2024 and granted for the worker's mixed use from 1 January 2025. In such cases, the legislature would naturally also have to decide which regime is applicable and more precisely whether it is the regime in force at the time the vehicle is granted or that of its registration'.

Copyright reserved ©
Loading...

Brand connect

Loading...

Newsletter

Notizie e approfondimenti sugli avvenimenti politici, economici e finanziari.

Iscriviti