Rottamazione quater, reopening seeks another possibility

Race against time for the finalisation of the other measures to be included in the tax decree. After the stops in the conversion of the Milleproroghe, there are several measures still on the waiting list. First and foremost, there is the mini-parachute for taxpayers who have opted out of the "rottamazione quater" scheme for not having paid the end-of-November instalment, and the suspension of the EUR 2 contribution on non-EU mini-packages in view of the new EUR 3 tariffs that will come into effect on 1 July. Then there are the other dossiers on which the technicians of the financial administration are working, such as the shield for condominiums in the case of incomplete work or irregularities in the superbonus (see Sunday's 'Il Sole 24 Ore') and the hyper-amortisation with the stop to the made-in-EU clause and the possibility of deduction also for those who enter into an arrangement with creditors.

But let us go in order. The reopening of the 'rottamazione quater' for taxpayers who were once again disqualified for having missed the 30 November 2025 instalment after having re-entered the race last year did not even go to the vote of the Chamber's Constitutional Affairs and Budget commissions, even though the measure had had the favourable opinion of the Ministry of the Economy, as its main supporter Alberto Gusmeroli (Lega) had remarked. The hypothesis of repechage in the tax decree was also confirmed by the deputy minister of the Economy Maurizio Leo: 'Let's see if we can recover that amendment. The evaluations are tied to the need to identify the coverage. But also to a revision of the regulation's structure. In fact, there would no longer be the technical time to set 28 February as the watershed for the return, with the margin of tolerance and the game of Saturdays and Sundays that would still lead to the possibility of settling the bill until 9 March. It will therefore be a matter of identifying a new deadline (it could also be at the end of March) by which both the end-of-November instalment and the instalment that the theoretical calendar (theoretical because once the plan has lapsed, it is as if it no longer exists) set for 28 February must be paid.

The other hot topic is that of the levy on non-EU minipacks. The agenda approved in the Milleproroghe represents a commitment for the government to find a solution in the tax decree. It could be a double move: first the postponement and then the stop. The EUR 2 contribution must, in fact, also come to terms with the new EU tariffs that will start on 1 July. While there do not seem to be any problems with the postponement, as underlined also by Economy Undersecretary Federico Freni in response to an M5S question in the Senate (see 'Il Sole 24 Ore' of 19 February), the real question arises with the entry into force of the new tariffs. It becomes necessary, in fact, to find the missing coverage (383 of the 612 million envisaged over the three-year period) to eliminate the contribution and leave the field completely open to the application of the new tariffs, 75% of which goes to the Community budget and only the remaining 25% is retained by the Member States as reimbursement for collection costs.

Then there is also the issue of the new rules for calculating VAT on exchange sales, which has created a number of interpretation problems for multi-year contracts. The manoeuvre has provided that as of 1 January 2026, the taxable amount for calculating VAT in exchange sales will be changed from the normal value to the costs attributable to the goods and services exchanged. This change has led to complications especially in multi-year contracts, resulting in a double calculation mechanism. To try to remedy the problem, a series of amendments had been tabled to the Milleproroghe, including one by Finance Committee chairman Osnato (FdI). The corrective measure that was later withdrawn, and therefore not put to the vote, aimed to make the measure take effect only from the new 2026 contracts, leaving a softer mechanism for contracts already in progress: with the old system still safe and the new one ready to be triggered from next year. In fact, this would translate into a mini-advantage in terms of revenue because the calculation with the normal value entails a cost of €15.3 million according to the estimates of the technical report to the manoeuvre: a cost that could therefore be at least partially postponed to 2027. One could, therefore, start from this very solution within the tax decree.