Tax decree, green light in committee: special amnesty approved

Green light for the amendment that re-proposes the special amnesty for the years 2019-2023. The amendment reformulated by Marco Osnato (Fratelli d'Italia) to the tax decree (Dl 84/2025) that reopens the amnesty on the past only for VAT numbers that will adhere to the two-year arrangement for 2025-2026 has been approved in the Finance Committee of the Chamber of Deputies. The correction (much awaited especially by those who have to decide on the concordat) had been shelved pending reformulation. The text of the decree, approved in a lightning session in the Commission, is expected in the House starting Monday. Then it will pass to the Senate for the second reading.

The rule on special amnesty, which is in fact a new amnesty, replicates the one already tried out last year at the debut of the concordato, moving its time limits forward. By accepting the Revenue Agency's proposal, self-employed persons and professionals will be able to settle their arrears with the tax authorities for the years 2019 to 2023. Those who adhere to the tax concordat for the first time in the two-year period 2025-2026 will have the opportunity to 'shield' the years between 2019 and 2023. On the other hand, those who adhered last year will be able to amnesty 2023, since the previous years have already emerged.

The amounts to be paid in tax relief vary according to each taxpayer's tax scorecard, the so-called Isa. In fact, the amendment establishes that the Irpef taxable base is made up of the difference between the business or self-employment income already declared in each year and the actual value increased by 5% for those with a reliability score of 10; 10% for those with a score of 8 to 10; 20% from 6 to 8; 30% from 4 to 6; 40% from 3 to 4; and finally 50% for those below 3. The substitute tax follows the same logic: those with a score of 8 or above will have to pay 10% of the undeclared income. Those with between 6 and 8 will have to pay 12% and those below 6 will have to pay 15%.

The IRAP rate, on the other hand, is the same for everyone and is 3.9%. For 2020 and 2021, the Covid years, there is an additional 30% discount. In any case, the total value of the tax to be paid cannot be less than EUR 1,000. The payment (these are the details reformulated in the committee) can be made in one lump sum between 1 January and 15 March 2026, or in a maximum of 10 monthly instalments plus interest.

Amongst the other amendments approved in committee, the corrective measure aimed at putting stakes on raids by the Inland Revenue and the Guardia di Finanza on companies, requiring that the authorisation acts and the minutes drawn up at the end of the audit be 'expressly and adequately indicated and justified the circumstances and conditions that justified the access'.