Italian Revenue Agency allows tax amnesty for certain taxpayers
Taxpayers who renewed their two-year preventive settlement agreements for 2026 and 2027 can regularize past fiscal years from 2020 through 2023 between January 1 and March 15, 2027, according to a directive issued by the director of the Italian Revenue Agency on October 23, 2026. Under Article 29 of Legislative Decree No. 148 of 2026, the special tax amnesty is restricted exclusively to taxpayers who previously joined the 2024–2025 preventive settlement agreement and renewed their commitment for the 2026–2027 period.
The directive allows participants to settle past years from 2020 to 2023 through the payment of substitute taxes on income, related surtaxes, and regional tax on productive activities (IRAP). This scope covers taxpayers who applied synthetic reliability indices (ISA), those who declared exclusion conditions tied to the epidemiological emergency from Covid-19, subjects declaring non-normal business operations, and operators carrying out multiple business activities not attributable to the same ISA where “non-ISA” revenues exceed 30 percent of the total declared amount.
Taxpayers Reference Declarations to Calculate Amounts Owed
To determine the amounts owed, taxpayers must reference tax declarations and ISA-relevant data existing as of the entry into force of Legislative Decree 148 on August 12, 2026. Attachment 1 of the agency’s provision identifies the specific declaration fields required to calculate the taxes due.
Taxpayers can choose whether to settle specific individual years or all four years. Ai fini della validità dell’opzione in tali circostanze, è necessario che vengano inoltrati tutti i modelli F24 concernenti le imposte sostitutive dovute: nello specifico, quello concernente l’Irap per conto della società o associazione, insieme a quelli relativi alle imposte sui redditi dei soci o associati, a meno che la società non vi adempia in prima persona.
Regularization Window Opens January 1 and Closes March 15
The regularization window opens on January 1 and closes on March 15, 2027. Interested parties can pay either in a single lump sum or through installment payments lasting up to a maximum of ten months. Meanwhile, taxpayers subject to ISA provisions faced a November 2 deadline to decide whether to accept the revenue proposal formulated by the Revenue Agency for the 2026 and 2027 period, a process coordinated with broader agency guidelines detailed in Circular No. 8/E.