Tax authorities: from letters to informal notices – here’s how the August reprieve works

It is not just about tax collection. The August reprieve, already provided for in relation to the dispatch and payment of friendly notices and alerts from the Revenue Agency, is now firmly enshrined within the Consolidated Act on Compliance and Tax Assessment (Legislative Decree 141/2026) published in the ‘Gazzetta Ufficiale’ on 6 August.

The Consolidated Act – which, like the other seven that have been passed, will come into force in 2027 – incorporates (Articles 338 to 340) the provisions already in force that provide a safeguard against requests from the tax authorities to taxpayers and the professionals assisting them during the month of August. This safeguard is, in fact, supplemented by thesuspension of the service of tax assessment notices. It should also be noted that this reprieve extends to tax litigation, with ‘the suspension during August of the time limits for challenging tax assessment notices and other tax documents’.

Apart from the suspension of tax payments and returns, the regulations introduced in recent years have put in place a series of safeguards to avoid inconvenience to professionals and advisers during the summer holidays. Thus, one of the implementing decrees of the tax authorisation law (Legislative Decree 1/2024) has established a moratorium on the dispatch of documents prepared and issued by the tax authorities throughout the months of August and December. This moratorium applies to informal notices and compliance letters. Voluntary settlement notices are those relating to communications arising from automated checks on tax returns, formal checks (those, for example, relating to supporting documentation for deductible or tax-deductible expenses) and the assessment of income subject to separate taxation (one example, amongst others, is severance pay). There are, however, exceptions relating to ‘cases of urgency and where a delay is not feasible’, which have already been clarified by the Revenue Agency (Circular 9/E/2024): situations where there is a risk to tax collection; the sending of notices or documents requiring the reporting of a criminal offence in the event of criminally relevant violations; or those addressed to parties subject to insolvency proceedings, to enable the filing of a claim against the estate.

However, the reprieve does not apply solely to the receipt of notices. From 1 August to 4 September, there is in fact a suspension of payments relating to automated assessments, formal assessments and tax assessments subject to separate taxation. This suspension of payments therefore also covers informal notices that may have been served in August where there were grounds of urgency or where payment could not be deferred; in such cases, the deadline for payment will still commence on 5 September.

Furthermore, from 1 August to 4 September, the deadlines for submitting documents and information requested from taxpayers by the Revenue Agency or other tax authorities are suspended. However, this suspension does not apply to deadlines relating to requests made during access, inspection and audit procedures, nor to those relating to VAT refund procedures.