Tax reform, here are the 22 adjustments for 2025. Concordat, losses and reserves drive implementation

With so many open dossiers, one should not be surprised by the extension of time: there will be 12 more months, until 29 August 2026, to issue the delegated decrees; and the single texts can be drafted by 31 December 2026. This is the provision of the extension bill (Ac 2384), approved in committee at the Chamber of Deputies and awaiting final approval before the summer break.

As for single texts, after the triplet at the end of 2024, only one has so far arrived in the Official Gazette this year, the one on tax collection. Since the effectiveness of these texts is deferred, there is another one on the way, on registration tax and other indirect taxes: the parliamentary commissions are called to express their opinion by 18 July; the Unified Conference is instead convened next Thursday. A further single text, on VAT, could be examined together with the new Irpef-Ires decree.

In terms of numbers, 56 second-level acts have been passed out of the 111 required by the delegated decrees to date. The percentage has remained stable for months around 50 per cent. This is not only because new legislative decrees are being added, but also because in some cases the law does not set a maximum number of implementing measures: suffice it to think of the strengthening of the digital services of the Inland Revenue, provided for by the Decree on Compliance (Legislative Decree 1/2024), from which four measures of the director of the Agency have resulted; the latest, in order of time, is the document of 2 April on the online application for the rectification of cadastral data.

The number of acts passed increases from 56 to 58 if we also count the two that intervened on chapters that had already been implemented: the Ministerial Decree of the Ministry of Finance of 25 June on the calculation of the hiring bonus and the Revenue Order of 3 June that extended the deadline for the simplified declaration of withholding tax.

The amendments to the legislative decrees in most cases did not generate new regulations to be implemented. But a new DM of the Mef will be needed in light of the fact that - starting in 2025 - the sending of medical expenses to the Ts system will take place annually. A chase between decrees, in short.

Implementing measures, however, must also be weighed, not just counted. This is why the first realignment measure on diesel excise duties (the Ministerial Decree of 14 May, which descends from Legislative Decree 43/2025) had a generalised impact. While it will be very relevant for companies and professionals the acceleration at the end of June, which saw the signing - among others - of the Ministerial Decree of the Ministry of Finance on the regime for the free movement of intragroup losses and on the extraordinary release of reserves (both signed on 27 June). Of course, many companies are also waiting for indications on the mini-Ires. But that comes from the manoeuvre for 2025, not from the tax delegation.