Scrapping 5, the countdown begins but it will not be for everyone

In the Scrapping quinquies, with the amendment to the 2026 manoeuvre approved in the Senate, the deferment interest is reduced from 4 per cent to 3 per cent. The rest of the system is instead confirmed, so that on the tax front, only deferments resulting from the automated control of income and VAT returns are affected. At this point, the perimeter of the future amnesty appears clarified.

The approach is very different from the past: whereas previously there was the rule that all the loads of the Agenzia delle Entrate Riscossione (Ader) could access the amnesty, with the exclusion of the items peremptorily indicated by law, in the discipline under review it is the list of the roles admitted that is peremptory. In fact, it includes the loads entrusted by 31 December 2023 that concern only and exclusively three categories of debts.

The PERIMETER

From tax debts to traffic fines

The first type is the tax one and includes the entries on the docket resulting from the settlement and formal control of income and VAT declarations. Given the wording of the bill, it is clear that it covers not only the hypotheses of the omitted payment of declared taxes, but the entirety of the findings arising from the procedures in question, such as the adjustment of deductions and withholding taxes declared. Since the amnesty is addressed to the items under the management of the Revenue Agency - Collection, the amnesty does not include the amounts that are subject to deferment on the basis of the reminder notices issued by the Revenue Agency as a result of automated controls, prior to the registration of the amounts due. Therefore, the new facilitated settlement does not cover, inter alia, all the enforceable assessments, acts concerning indirect taxes on transfers (registration, inheritance and donations) and local taxes.

Finally, fines from traffic violations are also potentially affected by the amnesty, if they were imposed by state administrations. On the other hand, those imposed by local police forces are excluded.

ADMISSION

Telematic application by 30 April

Given the difficulty of precisely identifying the items affected by the definition, the rule is confirmed that Agenzia delle Entrate Riscossione will make available to debtors, in the reserved area of its website, the list of the loads that can be included in the application. The application must be submitted only electronically by 30 April 2026. The advantage is represented by the fact that only the principal is paid, with zero penalties, interest, and collection surcharge, together with the cost of notifying the file and the reimbursement of any expenses for enforcement procedures.