The tax authority’s business mentoring scheme is proving increasingly popular: 224 companies have already been accepted

The tax authorities, acting as a mentor to businesses, are stepping up their efforts. And a further push is on the way following the wide-ranging circular (the 6/E/2026) signed on Thursday 6 August by the Director of Revenue Vincenzo Carbone and the amendments to the Omnibus Decree (finally approved on Tuesday by the Council of Ministers) at the instigation of the Deputy Minister for the Economy Maurizio Leo. The latest development is that the tally now stands at 224 companies admitted to the cooperative compliance scheme.

The list of participants is therefore growing compared with the last update, which stood at 221 at the end of 2025. These are significant increases, as the participants are, for the time being, very large companies. Suffice it to say that at the end of previous year, the monitored taxable income was estimated at around 49 billion euros. These figures explain why the tax authorities are investing in this corporate disclosure regime, under which companies are required to certify their tax risk management systems, followed by an accompanying audit by the Revenue Agency.

At present, the main entry point to the scheme is the threshold of 500 million euros in turnover (provided the requirements are met, it is also possible to enter via other ‘side’ routes, such as the advance ruling for new investments). However, from 2028, the threshold will be lowered to €100 million, as set out in the timetable for the implementation of the tax reform. This expansion could come to encompass a further 11,000 businesses. Without forgetting, however, the most critical challenge: the optional entry of SMEs that fall below the size threshold. This is first and foremost a cultural challenge: overcoming the hurdle of the initial costs involved in establishing and certifying the Tax Control Framework (TCF) may yield future benefits not only in dealings with the tax authorities but also, amongst other things, with stakeholders and the financial and banking sectors in terms of access to credit.

The Omnibus Decree provided a further incentive to join the scheme. As well as extending the deadline for TCF certification to 31 December for companies that applied to join in 2024 and 2025, the measure addresses tax risks arising prior to joining the scheme. This includes the option to defer tax liabilities in up to 20 quarterly instalments, without incurring penalties for voluntary disclosure. This opportunity provides greater peace of mind, particularly regarding the more complex issues that may be subject to differing interpretations between the tax authorities and the taxpayer. This is the case, for example, with discrepancies relating to the application of international accounting standards.

The action plan is, in fact, a sort of extension of what is already in place for companies that meet the size criteria to join the cooperative compliance scheme. Therefore, disclosures of past tax risks must be ‘made without delay within 120 days of notification of the decision to admit the company to the scheme’ but, above all, they must be made ‘before the taxpayer has formally become aware of any accesses, inspections, audits or the commencement of any administrative assessment or criminal investigation relating to the risks reported’.