Tax reform: 7 out of 10 regulations missing

It is probably no coincidence that the decree on compliance has the highest implementation rate (40 per cent): in many cases, a measure signed by the director of the Inland Revenue was sufficient to translate the legislative rules into concrete terms. On the contrary, the slowness of processes requiring opinions from other authorities such as the Privacy Guarantor or "concerts" with other ministries is confirmed.

When all is said and done, the 17 provisions cited have been implemented through 12 provisions of the Inland Revenue (counting together those adopted to simplify the declaration models), and nine ministerial decrees of the MEF, of which only one arrived in agreement with the Ministry of Labour: it is the Ministerial Decree of 25 June 2024 that regulates the hiring bonus and was published in the Gazzetta on 3 July, six months after the entry into force of the Irpef-Ires decree (Legislative Decree 216/2023).

So far, the order of priorities has been dictated by the urgency of the measures that 'had' to be enacted by a certain date (such as the list of acts excluded from the cross-examination between the tax authorities and taxpayers) or were indispensable to start the tax agreement operation (such as the two Ministerial Decrees published at the beginning of July with the methods for calculating the income proposed to Isa taxpayers and flat-rate taxpayers).

In many cases, the provisions of the legislative decrees do not dictate precise deadlines. This is the case, for instance, for the new rules on fee-based appeals and answers processed by artificial intelligence or for possible improvements in taxpayer services (enrichment of the tax drawer, dialogue with the Portal for Municipalities, F24 payable with PagoPa, and so on). Among the regulations that instead indicate a deadline - again, in truth, ordinatory, i.e. non-binding - there are several in the Dlgs on international taxation: the counter stops at three implemented measures out of eight, two of which are missing and with deadlines that have already expired. It has to be said, however, that many foreign countries are moving more slowly than Italy in the transposition of the global minimum tax, on the fate of which many clouds are gathering.

Logically, all the second-level measures provided for in the decrees published at the beginning of August still remain to be implemented. While it is true that the corrective decree does not have any specific regulations (except for a tweak to a provision of the compliance decree) and the decree on sanctions contains only one, the implementation of the decree on collection promises to be very challenging. In order to regulate the relationship between the collection agent and creditors, but also to establish when citizens and businesses will be able to defer debts up to 120 instalments, an impressive set of provisions will be needed: six Ministerial Decrees of the MEF, two of which are subject to agreement at the Unified Conference, another Ministerial Decree of the MEF in agreement with Labour (again subject to agreement at the Conference), a ministerial regulation, and a document on the institutional website.

Also still at a standstill are the measures of the gaming decree (Legislative Decree 41/2024), which often require regulations of the Mef on the proposal of the Customs and in some cases imply consultation with other bodies: the Ministry of the Interior, the Ministry of Health and the Bank of Italy.