Towards the Budget Bill

Taxation: the budget focuses on a further increase in the Tobin tax on share purchases

Part of the 5 billion sought from the financial sector as a result of the increase in the financial transaction tax. The package of measures also includes a restriction on the transfer of deferred tax assets (DTAs)

Manovra 2027, mercoledì il Cdm: al centro famiglie, fisco e imprese

4' min read

Translated by AI
Versione italiana

4' min read

Translated by AI
Versione italiana

The banking package is taking shape ahead of the budget bill’s presentation to the Council of Ministers on Wednesday. Among the key elements of the package of measures – which, according to the Draft Budgetary Plan (DPB), is expected to generate 5 billion in additional revenue from the financial sector – is a restructuring of the IRES surcharge, which currently stands at 3.5 per cent, thereby raising the tax rate to 27.5 per cent compared with the standard rate of 24 per cent. The proposal currently under consideration is to raise the bar even further, bringing the tax threshold very close to 30 per cent. This is a proposal on which politicians will seek common ground with the banking and insurance sectors in the coming hours. In particular, senior representatives of credit institutions have sent messages to the Government highlighting a rift in the agreement that had already led, last year, to calls for a greater contribution in terms of tax revenue. ‘A delicate balancing act’ is the approach outlined yesterday by Deputy Prime Minister Antonio Tajani.

This is another reason why the measures in the dossier will be varied. It therefore appears that a further increase in the financial transaction tax and a freeze on DTAs (deferred tax assets) for the year 2027 are set to go ahead, with the possible disposal of tax credits arising from those DTAs.

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The increase in the Tobin tax

For financial transactions, the proposed measures would aim for an increase of two decimal points. If the ideas currently under consideration are confirmed, the levy on the purchase of shares, equity-linked financial instruments (SFP) and representative securities on regulated markets or multilateral trading facilities (MTFs), with a market capitalisation of 500 million euros or more, could rise from the current 0.20 per cent to 0.40 per cent of the value of individual transactions. Meanwhile, for the purchase of shares outside regulated markets or MTFs, the levy of 0.40 per cent would rise to 0.60 per cent. As was the case last year, high-frequency transactions – most often carried out for speculative purposes – will not be exempt from the increase: in this case, the Tobi Tax rate would rise from 0.04 per cent to 0.06 per cent.

The previous increase, due to take effect from 2026

The latest increase in the Tobin Tax is in line with the approach already set out by the government, namely that at this time all sectors capable of contributing will be called upon to do so. Furthermore, the government’s decision last year to raise funds through stock market transactions has borne fruit. This is clearly demonstrated by the monthly tax revenue figures. Last year’s forecasts indicated that doubling the financial transaction tax from 0.10 per cent to 0.20 per cent and from 0.20 per cent to 0.40 per cent and further from 0.02 per cent to 0.04 per cent for high-frequency trading was expected to generate an additional 337.3 million euros. This revenue estimate had raised concerns amongst experts in the Chamber of Deputies and the Senate, as the methodology used in the estimate did not appear to ‘take into account the possible disincentive effects on trading activity, and the consequent risk of erosion of the tax base, resulting from an increase in tax rates’.

Manovra 2027, mercoledì il Cdm: al centro famiglie, fisco e imprese

Revenue on the rise

The facts have shown that tax revenue has increased. The latest tax revenue statistics for the first eight months of 2026, published on the Department of Finance’s website, reveal that, as at 31 August, the State had already collected just under a billion from the Tobin Tax – 917 million to be precise, representing a 94.3 per cent increase in revenue compared with the same period in 2025, effectively dispelling all the controversy surrounding the slump in stock market trading that had accompanied the Tobin Tax increase at the end of 2025.

Tighter restrictions on the sale of receivables

Among the measures designed to ensure funding for the forthcoming Budget Bill – which will affect the financial and insurance sectors – deferred tax assets (DTAs) feature once again this year. And this year, there are two separate measures. On the one hand, banks, insurance companies and businesses will be barred throughout 2027 from converting DTA (deferred tax assets) or deferred tax liabilities into tax credits that can then be used for offsetting. On the other hand, there is the possibility of transferring tax credits arising from DTA. In fact, the idea on the table is to tighten the grip on the increasingly frequent fraud involving DTAs. The Guardia di Finanza has long been sounding the alarm about this phenomenon, which follows a similar pattern to the fraud involving Superbonus tax credits. The most recent operation, carried out last September by the Provincial Command of the Guardia di Finanza in Naples, uncovered a fraud involving tax credits from non-existent DTAs, amounting to over 133 million euros. In this case, the ‘shell’ companies – that is, companies that issue false invoices, two based in Naples and one in the province of Latina – – although not operational – had submitted fabricated tax returns capable of generating tax credits worth millions, to be used to offset taxes due or to be sold to third parties.

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