The two-year agreement will feature prominently in the Tax Code

The Tax Code will also include for the two-year composition with creditors (CPB). The long and complex work (particularly due to the constant stream of regulatory changes) of the expert commission, which is attempting to bring order to the tangled web of Italian tax rules, is beginning to see the finish line on the horizon. This was outlined by the Deputy Minister for the Economy Maurizio Leo during a hearing before the Parliamentary Supervisory Committee on the Tax Register: ‘The culmination of the tax reform will bethe Tax Code on which we are working, and I believe that by October we will be able to present the text to the Council of Ministers”.

It will serve as a kind of culmination of the entire delegated legislation. The text of Law 111/2023 itself – the law that sets out the scope of the reform – provides for the creation of a single reference point capable of bringing together the tax provisions. Complete with objectives set out in black and white: ‘To simplify the tax system and enhance the clarity and accessibility of tax rules, the certaintyof legal relationships and the efficiency of the work of the tax authorities’. In other words: legal certainty. An expression that is almost a pipe dream for taxpayers and professionals, who every day grapple with the difficulty of navigating a framework that is often hard to interpret due to inconsistencies or a lack of coherence resulting from successive legislative changes over time.

For all these reasons, the Tax Code represents a turning point. The structure will be as outlined by Leo during the hearing: ‘It will be organised into a general section , which will contain provisions on taxpayer rights, tax assessment, collection, penalties, litigation, and a special part which will essentially consist of the consolidated laws covering direct taxes, VAT, minor taxes and so on”. It is precisely in this general section that the institution of the composition with creditors will also be included; since its creation, this has undergone continuous refinement in an effort to enhance or maintain its appeal.

After all, the process by which the tax authorities propose income to a total audience of 2.7 million businesses and self-employed individuals based on tax reports (ISA) is structural. Therefore, the outlook (or at least the current political will) is for it to remain in place over time. And it is no coincidence that the implementation of the enabling act, through the 21 legislative decrees (including corrective measures) and 8 Consolidated Acts, has focused, in terms of development and explanation, on the tax settlement and collaborative compliance (the cooperative compliance) in an attempt to change the relationship between the tax authorities and taxpayers.

The concept of the Consolidated Acts, which serve as a prelude to the Code, also forms part of the effort to bring order and clarity to relations with the tax authorities. As mentioned, the Consolidated Laws will remain in the special part of the Code, as they will serve as a guide for determining individual tax liabilities: from the calculation of the tax base to the determination of the tax due.