Energy: 1.7 billion tax coupons targeted for advance tax payments

By selecting those companies that plan to pay dividends in instalments over two consecutive years, it is estimated that the proposed legislation would affect 1.696 billion in dividends on an annual basis. Based on an average tax rate of 19.7 per cent, the technical report therefore quantifies the additional revenue as 130.3 million, taking into account the application of the 39 per cent rate introduced on a provisional basis by the decree. It should be noted that this amends the Consolidated Income Tax Law (Tuir) accordingly by introducing the new Article 55 bis to bring the advance measure into full effect; consequently, it does not appear to be of an emergency nature.

The technical report naturally also focuses on the temporary cut in excise duty on motor diesel – the central element of the measure recently adopted by the government – to estimate the shortfall in direct revenue from excise duty on ordinary diesel, which amounts to 66.6 million euros. However, the document clarifies that to this figure must be added the losses arising from the knock-on effect of the reduction on the preferential rates applicable to agricultural diesel (-1.1 million) and to diesel used in stationary engines (-0.2 million). A further shortfall of €1.4 million stems from fuels (biodiesel and diesel obtained from renewable and waste raw materials) linked to the concessions provided for in Legislative Decree 43 of 2025.

The estimate also includes the cash flow effects arising from refunds granted for commercial diesel (ranging from taxis to the armed forces): the change in the tax rate creates a time lag, the report explains, between the payment of the full tax and the adjustment, resulting in an accounting impact of -23 million on excise duty, which is then offset by refunds amounting to 0.2 million in 2026 and 22.7 million in 2027.

Taking into account the indirect effects on VAT and the deferrals on IRES and IRAP, the gross impact of the excise duty cut on the State budget amounts to a loss of 105.6 million in 2026, compared with a recovery of 25.4 million in 2027 and a marginal decrease of 1.2 million in 2028. Net of the share of revenue allocated to the special-status regions, the net balance is -100.3 million in 2026, +25.3 million in 2027 and -1.1 million in 2028.

Finally, the technical report identifies the effects of the fiscal tightening on legal gambling. On the one hand, 2.6 million in 2026 and 25.4 million in 2027 are earmarked for the refinancing of the Fund for Structural Economic Policy Measures (Fispe), drawing on the increased revenue guaranteed by Article 2. On the other hand, as mentioned, the provision introduces tax measures for legal gambling licence holders, firstly by quantifying investments in responsible gambling awareness campaigns against gambling addiction (estimated by the Customs and Monopolies Agency at 3 million in 2026 and 7 million in 2027) as entertainment expenses under Article 108 of the TUIR and therefore subject to specific deductibility limits.

At the same time, expenses incurred for sponsorship or indirect promotion relating to licensed legal gaming operators are not deductible for IRES and IRAP purposes.

On both counts, however, the technical report remains non-committal, identifying potential positive financial effects which, for the sake of caution, have not been estimated in advance: the line taken is that any additional revenue will be used to further increase the FISPE.