Fisco

Corrective Decree, company cars: 50 per cent tax increase for old diesel and petrol

Additional options come in a flat rate of 5 per cent. Inheritance and gift tax: advance payment on trusts and liens

by Marco Mobili and Giovanni Parente

Aggiornato il 4 giugno 2026 alle ore 13:20

3' min read

Translated by AI
Versione italiana

3' min read

Translated by AI
Versione italiana

Changing course for the taxation of company cars. With a double gear included in the corrective decree of the tax delegation, initially expected in the Council of Ministers for Wednesday 4 June but for which a few more days will be needed for the fine-tuning of the whole articulation:
1) one aims at resolving a series of knots left open after the 2025 manoeuvre with which the government had intervened on this type of fringe benefit to reduce environmentally harmful subsidies (Sad);
2) the otherincreases by 50% the tax levy on old diesel and petrol models held in the car fleets of companies for more than five years. 

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A measure that aims to discourage corporate use of older and potentially more polluting cars, pushing companies to turnover their fleets every four years.

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Among the most important changes is also the one that revises the taxation rules for optional extras not included in the standard tariff of theACI tables: according to the Revenue's interpretation, the additional optional extras would have increased the tax burden on the vehicle granted to the employee for mixed use.

Whereas with the upcoming amendment the value of the fringe benefit is increased by a flat rate of 5 per cent.

As repeatedly requested by companies, the transitional tax regime for cars booked in 2024 and assigned throughout 2025 is also revised.

In this way, the possibility of normal value taxation of vehicles assigned to employees after 30 June 2025 is definitively averted.

 

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Also on the fringe benefits front, finally, stop possible penalties for companies that reassign vehicles previously granted to other employees.

But the Omnibus corrective goes further.

As announced at Telefisco 2026 by Deputy Minister for the Economy Maurizio Leo, Article 4 intervenes on the transfer of tax credits by professionals: any capital gains will become (for the amounts acquired from the date of entry into force of the decree) miscellaneous income and will therefore be taxed at 26 per cent and not at the ordinary Irpef.

As always for professionals, the taxation of the transfer of the entire firm is regulated.

The corrective decree then intervenes to define the perimeter of dependents (which determines the eligibility for bonuses for expenses incurred in their favour) and for the taxation of income in agriculture.

As well as oninheritance and gift taxes: here the possibility of advance payment of levies is granted in the case of trusts and destination bonds.

Rich then is the package ofmodifications on cooperative compliance.

Here comes the possibility, for companies adhering to the tutoring scheme, to regularise the past with regard to possible interpretative misalignments mainly related to the application of international accounting standards.

It also changes the global minimum tax where the discipline of the qualified coexisting regime, the qualified parent regime and qualified tax incentives is added. Precisely with regard to the latter it is specified that these are those based on the costs incurred or the level of production carried out in a country, which rdetermine the amount of relevant taxes.

In the area of financial income, there will be anincrease from 11% to 20% of the withholding tax on dividends paid on European pension funds.

More flexibility then for exercising the right to VAT deduction that can be claimed within the second year, allowing more oxygen in the case of late invoices.

It is precisely on the electronic invoice that data can also be used in customs risk analysis.

While the one-year reduction of assessment deadlines for flat-rate taxpayers is overridden, as e-invoicing is now mandatory for them as well.

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