Below, we examine the new provisions introduced by Law No. 199 of 30 December 2025 regarding “rottamazione quinquies” (clearing of historic tax debts), tax credits, and new tax rules relevant to businesses and professionals.
CONTENTS
- “Rottamazione” of tax rolls: reopening for debts assigned up to 31 December 2023
- Adherence to “rottamazione” and operational deadlines
- Fiscal and procedural effects of the facilitated settlement
- Payment methods and instalment plan up to 2035
- Taxpayers excluded from previous settlements and management of pending litigation
- Prohibition of set-off and reduction of the threshold to €50,000
- Supplementary pensions and incentives for business investments
- IRPEF surcharges and extension of the transitional regime for income brackets
- Traceability of travel and representation expenses
- Impacts on businesses and rules for representation expenses
1. “ROTTAMAZIONE” OF TAX ROLLS: REOPENING FOR DEBTS ASSIGNED UP TO 31 DECEMBER 2023 ↑
The 2026 Budget Law introduces a new facilitated settlement for debts assigned to the collection agent, commonly referred to as “rottamazione quinquies”, applicable to debts transmitted from 1 January 2000 to 31 December 2023. The relief mainly covers:
- missed payments arising from submitted tax returns,
- outcomes of automatic liquidation and formal checks,
- declared but unpaid social security contributions.
Also included are debts relating to penalties for violations of the highway code imposed by state administrations, limited to the cancellation of interest and surcharges. Excluded, however, are amounts arising from enforceable assessments, liquidation notices, recovery of tax credits, or independent penalty disputes. The main advantage is the elimination of administrative penalties, interest registered in the roll, late payment interest, and collection charges where still applicable. The collection agent will provide information tools to allow taxpayers to check in advance which debts may be settled.
2. ADHERENCE TO “ROTTAMAZIONE” AND OPERATIONAL DEADLINES ↑
Access to the facilitated settlement requires submission of an online application, according to procedures to be made available by the collection agent. The final deadline for submission is set at 30 April 2026, after which it will not be possible to access the benefit. By 30 June 2026, the administration will communicate the amounts due and the payment plan. Full payment or the first instalment must be made by 31 July 2026, from which point the taxpayer’s position will be considered regular for the purposes of the facilitated settlement. Managing these deadlines is therefore strategic for businesses and professionals, especially in cases of significant tax or social security exposures. It is advisable to carefully assess the economic convenience of adherence and verify the correct inclusion of debts within the scope of the law, avoiding errors that could compromise access to the benefit.
3. FISCAL AND PROCEDURAL EFFECTS OF THE FACILITATED SETTLEMENT ↑
Submitting the application produces immediate effects operationally and in relations with the tax authorities. The debtor is no longer considered in default for tax and social security purposes, resulting in the suspension of enforcement procedures and the inability to initiate new garnishments. Precautionary measures already adopted, such as administrative stops or mortgages, remain effective until payment of the first instalment. Among the significant effects is the possibility to receive payments from public administrations and to obtain the DURC certificate, which is crucial for participating in tenders and contracts. Furthermore, until 31 July 2026, payment obligations relating to previous instalment plans are suspended. Payment of the first instalment results in the termination of ongoing enforcement procedures, including third-party garnishments, provided the sums have not already been allocated. These effects reinforce the role of “rottamazione” as a tool for financial regularisation and revitalisation of business operations.
4. PAYMENT METHODS AND INSTALMENT PLAN UP TO 2035 ↑
The legislator allows the taxpayer to choose between full payment by 31 July 2026 or an instalment plan of up to 54 bi-monthly instalments, spread between 2026 and 2035:
- the first three instalments are due on 31 July, 30 September, and 30 November 2026;
- from 2027, deadlines follow a predetermined bi-monthly schedule;
- the final three instalments are concentrated in the first months of 2035.
In the case of instalment payments, from 1 August 2026, interest at 3% per annum will apply. The possibility to extend the plan up to ten years represents a significant opportunity for businesses and taxpayers facing liquidity difficulties, but requires careful financial planning to avoid future defaults. The choice between immediate settlement and instalment payments should be evaluated considering the cost of interest and the impact on business cash flows.
Loss of facilitated settlement and operational consequences
The rules are particularly strict in the event of non-payment. The facilitated settlement loses effectiveness if the single instalment is not paid, or if two instalments (even non-consecutive) or the final instalment are missed. The usual five-day grace period applied to other instalment schemes does not apply. In the event of loss of benefit, all penalties, interest, and collection charges originally cancelled are reinstated in full. The possibility to resume previous instalment plans or request new ones after loss of benefits remains uncertain, which requires careful consideration before joining. “Rottamazione quinquies” should therefore be seen as an effective but binding tool, requiring accurate financial management and prior verification of the sustainability of the instalment plan.
5. TAXPAYERS EXCLUDED FROM PREVIOUS SETTLEMENTS AND MANAGEMENT OF PENDING LITIGATION ↑
The new measure also allows access for taxpayers excluded from previous facilitated settlements, provided the debts are eligible and mainly arise from declared but unpaid amounts. However, those who were up to date with instalments of the previous “rottamazione” as of 30 September 2025 cannot access the new procedure and must continue with the original plan. A relevant aspect concerns ongoing disputes. Adherence to “rottamazione” requires commitment to waive pending litigation relating to the debts being settled. After submitting the application, it is possible to request suspension of the proceedings. Payment of the first instalment results in the termination of the dispute and the loss of effectiveness of any judgments already issued. This provision requires strategic evaluation with tax advisors, especially where the dispute has significant prospects of success.
6. PROHIBITION OF SET-OFF AND REDUCTION OF THE THRESHOLD TO €50,000 ↑
The new Budget Law changes the rules for offsetting tax credits, introducing a significant reduction in the threshold of debt registered in the roll that prevents offsetting. The limit drops from €100,000 to €50,000 and also applies to debts arising from enforceable assessments or recovery of tax credits. The prohibition applies to the entire offsettable amount, not just the excess over the debt. Therefore, even with credits exceeding the debt, offsetting is blocked until the position is regularised. The prohibition does not apply if an instalment plan is active or if a “rottamazione” application has been submitted. The new threshold should apply to offsets made from 1 January 2026, based on the date of execution of the payment mandate. The rule requires more careful management of tax credits, especially for businesses with high volumes of offsets.
7. SUPPLEMENTARY PENSIONS AND INCENTIVES FOR BUSINESS INVESTMENTS ↑
Among the relevant tax measures is the increase in the annual deductibility limit for contributions to supplementary pension schemes, which rises from €5,164.57 to €5,300 from the 2026 tax year. The increase applies to both voluntary contributions and those paid by employers or clients and is coordinated with the rules for workers first employed after 2006. In parallel, the legislator introduces a 4.0 tax credit for the agriculture, fishing, and aquaculture sectors for investments made between 2026 and 2028, with a rate of 40% up to €1 million. The Sabatini Law is also refinanced with new resources for 2026-2027, confirming support for productive investments by SMEs. These measures are complemented by further refinancing of the 4.0 tax credit and the extension of the bonus for design and aesthetic innovation, set at 10% with an annual limit of €2 million. In the context of the energy transition, a 5.0 tax credit is also provided for energy-intensive businesses.
8. IRPEF SURCHARGES AND EXTENSION OF THE TRANSITIONAL REGIME FOR INCOME BRACKETS ↑
The law extends until 2028 the transitional regime allowing regions and municipalities to apply IRPEF (personal income tax) surcharges using the previous four income brackets in force in 2023. Territorial entities can therefore continue to differentiate rates based on bands up to €15,000, between €15,000 and €28,000, between €28,000 and €50,000, and above €50,000. For the 2026 tax year, the deadline for municipalities to decide on the application of the old brackets is extended to 15 April 2026. In the absence of new resolutions, the rates and brackets already in force in the previous year will continue to apply. The measure aims to ensure stability during the transition to the new IRPEF structure, avoiding sudden changes in the tax burden for taxpayers and businesses.
9. TRACEABILITY OF TRAVEL AND REPRESENTATION EXPENSES ↑
Regulatory changes clarified by the tax authority’s circular introduce important new rules on the traceability of expenses incurred for travel and representation. For employees, documentation for municipal travel is simplified, allowing any suitable proof and maintaining tax exemption for properly documented reimbursements, including mileage reimbursements based on “ACI” tables.
From 2025, however, expenses for meals, accommodation, and transport by taxi are tax-relevant only if paid using traceable instruments, a requirement that also extends to tourist tax and services intermediated by digital platforms. For self-employed workers, the same expenses are included in income if not paid with traceable means, but remain deductible when recharged analytically to the client and paid with electronic instruments. Traceability also becomes an essential requirement for the deductibility of expenses relating to assignments given to other professionals and for analytical reimbursements.
10. IMPACTS ON BUSINESSES AND RULES FOR REPRESENTATION EXPENSES ↑
For businesses, the new provisions directly affect Articles 95 and 109 of the TUIR (Italian unique tax code). From the tax period after 31 December 2024, expenses for meals, accommodation, travel, and taxi transport are deductible only if incurred with traceable means and relate to operations carried out within the national territory. For services provided by self-employed workers engaged by the company, the new Article 109, paragraph 5-ter applies, while relations with employees and collaborators continue to be governed by previous rules.
Regarding representation expenses, Article 108 of the TUIR makes deductibility conditional on traceable payment from 2025, without distinction between expenses incurred in Italy or abroad. Advertising and sponsorship expenses remain excluded from this requirement and retain their separate regime. The new rules directly affect the determination of the IRES (corporate income tax) and IRAP (regional tax on the net production value of businesses) taxable base and require businesses to adapt internal reporting and payment control processes, with particular attention to the retention of fiscal documentation.
