Short rentals, the new squeeze starts from the third rented property
The limit at which entrepreneurial activity is presumed to exist and a VAT number has to be opened will fall. Owners will be burdened by higher taxation but also a higher burden of obligations
The fiscal squeeze on short-term rentals is set in motion immediately. From 1 January the new system, designed by the Budget Law 2026 (199/2025), came into force after much controversy within the majority. Starting from the third property rented out for tourist purposes, therefore, it will be compulsory to open a VAT number, because it will be presumed that a business activity is being carried out. To this mini-restriction, which will affect just a few thousand properties, another could soon be added, which will start from the bottom, i.e. from the regions and municipalities, and could concern administrative and town-planning profiles of management of the phenomenon. Even if, on this point, case law will also weigh in.
The taxation regime
Starting with the tax profiles and the rules just supplemented by the Budget Law, the manoeuvre has maintained the current taxation system on the first property rented out on a short-term basis, taxed at 21% with the cedolare secca, and on the second, which will instead be taxed at 26%, again with a substitute tax. It must be remembered that the 26% rate has been introduced as of 2024 and that, until now, it was possible to opt for the 21% rate, within the 730, for only one property.
The new obligation
Now the system changes from the third property rented for less than 30 days: in this case, the obligation to open a VAT number is triggered; until 31 December 2025 the presumption of entrepreneurial activity was linked to the limit of the fifth property rented. This ceiling will be lowered from 2026 but, in any case, will only result in VAT registration being applied to a few thousand more properties. Very few, in a perimeter that now covers in Italy approximately 500 thousand houses today present on the various online platforms. From these rentals will come greater Irpef revenue (outside the perimeter of the coupon tax) that the technical report of the 2026 Budget Law estimates at 13 million each year, when fully operational. All in all, very little for a sector that in the first eight months of 2025, according to the estimates of Fiaip real estate agents (contained in a study drawn up together with Fimaa and Anama), mobilised over 8 billion euros of bookings.
There is, however, not only the higher taxation to be considered as an unfavourable element for owners (because in some cases it will be possible to defend oneself by entering the flat-rate regime), but at least two other factors. With the VAT number comes the obligation to pay social security contributions, which greatly increase the charges paid at the end of the year. In addition, an accountancy must be kept, which, in terms of fulfilment, is considerably more complex than just paying the coupon, due to the management of invoices and VAT.
However, many landlords will try to circumvent the new three-property limit. They will be able to put the third house in the name of children or relatives, rent it out on a long lease, give it on loan, and then start subletting, or run their business in the black. These are all paths on which the tax authorities will then carry out their checks, punishing evasion and avoidance, but which, in any case, will make the new rules inapplicable in a great many cases in the immediate future.
