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VAT numbers, fiscal pact 2025-26: in the North and in services half of those affected

The new edition of the arrangement procedure targets 2.3 million Isa subjects, of which only 950,000 have at least a grade 8 on their report card. Applications by 30 September

by Dario Aquaro and Cristiano Dell'Oste

3' min read

3' min read

The two-year concordat with the Inland Revenue reopens its doors and looks to the North and to the service sector: two areas in which about half of the 2.3 million potential beneficiaries fall. Many are those who will have to decide whether or not to adhere to the new proposal drawn up by the Revenue software for the two-year period 2025-26.

The pool of those affected can be estimated by difference starting from the total number of taxpayers subjected to the Isa tax report cards last year (2.7 million) and excluding the 460,000 who signed the pact for 2024-25.

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The deadline for formalising the choice is 30 September. The publication in the Official Gazette of the corrective decree (Decree 81/2025) has put in black and white the rules that will guide this second edition of the tax concordat. Flat-rate taxpayers will be excluded from this year: for them, the 2024 annual edition, which saw 124,000 registrations, seems destined to remain unique.

Lombardy lead

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Half of the companies and self-employed affected - 1.1 million Isa subjects - are based in the northern regions, with Lombardy leading the way (418,000 taxpayers), followed by Veneto, Emilia Romagna and Piedmont, all between 210 and 160,000.

The territorial distribution of the audience, on closer inspection, follows the general distribution of enterprises. And this is because, from this point of view, the adhesions to the first agreement did not shift the balance between one region and another: from the lowest in Sardinia (below 10% of options out of the total number of Isa subjects) to the highest in Trentino Alto Adige (above 21%).

At the sectoral level, again among Isa subjects, the self-employed and companies operating in services gather a little more than half of those interested for the two-year period 2025-26: about 1.2 million out of 2.3. This is followed by commerce (422,000 contributors) and the professions (394,000).

Concordato preventivo biennale: cosa cambia dopo le modifiche del correttivo

Test at 200,000 for membership

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The data on the first round show a different sensitivity of companies according to their tax reliability rating: among those who scored at least 8 on the Isa, adhesions were around 22 per cent; among those who received lower scores, they were around 12 per cent.

Therefore, based on the declarations submitted in 2024 - which have just been published by Finance - it can be assumed that there will be 1.3 million Vat parcels affected by the 2025-26 arrangement with a grade below 8 and about 950,000 with at least an 8 on their report card.

Theoretically, if the acceptance rate of the IRS proposals remained the same as in the first edition, the pact for 2025-26 would obtain just under 200,000 adhesions. This is, of course, abstract reasoning, because we do not yet know the Isa 2025 report cards and because the impact of regulatory changes and the algorithm that will calculate the proposed income will have to be seen in practice.

A company that experienced a drop in turnover in the 2024 tax year will lower the basis of calculation and receive a lower - and perhaps more attractive - 2025-26 proposal for an arrangement than the 2024-25 proposal.

Those with a rating higher than 8 will also benefit from the cap on the maximum income increase proposed by the IRS. On the other hand, associated firms or companies with many partners may be held back by the fact that changes in the corporate structure, which are not always predictable, will lead to the forfeiture of the agreement. It will also have to be taken into account that - for the time being - the package of benefits offered in 2025-26 lacks the tax amnesty on past years, which is instead combined with the 2024-25 agreement. But here one cannot exclude interventions by Parliament, perhaps in the conversion of the tax decree.

It is clear that much of the success of the next round of concordat will depend on the ability to engage the self-employed and businesses with the worst marks. In the service sector - the one with the widest potential - there are the categories with the highest incidence of those below an 8 on the report card: from car rental businesses (81.3%) to nightclubs (77%), from laundries (75.8%) to restaurants (74.5%).

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