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Italy’s consolidated Act on tax compliance and assessment: new article numbers from 2027 for rules that are largely unchanged

Legislative Decree No. 141 of 5 August 2026 approves the consolidated Act on tax compliance obligations and assessment (testo unico adempimenti e accertamento), which applies from 1 January 2027. The rules on returns, audits and assessment move and are renumbered; in substance they largely remain those in force today, although some changes have already been made.

The consolidated Act brings together, among other things, most of Presidential Decree No. 600/1973, the provisions of Presidential Decree No. 633/1972 on audit and assessment powers, Presidential Decree No. 605/1973 on the tax database (anagrafe tributaria) and the rules on assessment by agreement with the taxpayer (accertamento con adesione) in Legislative Decree No. 218/1997. In brief:

• until 31 December 2026 the current provisions continue to apply;
• from 2027 the statutory references change: for example, Article 159 for the powers of tax offices and Article 293 for the time limits for income tax and VAT assessments;
• many provisions are carried over without substantive changes, but some amendments were made to the consolidated Act even before it applies.

This Act and the other seven

Legislative Decree No. 141 of 5 August 2026 was published in Official Gazette No. 181 of 6 August 2026 (ordinary supplement No. 28) and entered into force the following day, but the provisions of the consolidated Act apply from 1 January 2027 (Article 368). It was adopted under Article 21, paragraph 1, of Law No. 111 of 9 August 2023, the enabling law for the tax reform, which entrusted the Government with reorganising tax legislation into consolidated Acts. The same decree also contains coordinating and corrective provisions for the other consolidated Acts already approved.

From 1 January 2027 eight consolidated Acts will apply together; each of them takes effect on that date:

How the Act is organised

As published, the consolidated Act has 368 articles, divided into three parts.

• Part I, compliance obligations, notifications and returns (Articles 1 to 88). It covers the tax database and the tax code (codice fiscale) (Articles 1 to 14, which, according to FiscoOggi, take over Presidential Decree No. 605/1973 except for the final and transitional provisions no longer in force and the penalty provisions), the register of financial relationships, income tax compliance obligations, elections, notifications and tax returns.
• Part II, cooperation, audits and assessment (Articles 89 to 363). It covers the two-year preventive agreement (concordato preventivo biennale), the cooperative compliance regime, international advance agreements, the powers of tax offices, administrative cooperation, the automated processing and the formal review of returns, the assessment of income taxes, VAT, registration tax and minor taxes and, in Articles 345 to 363, assessment by agreement with the taxpayer. Articles 1 to 17 of Legislative Decree No. 218/1997, which currently governs that procedure, are among the provisions repealed by the consolidated Act (Article 367, paragraph 1, point (bb)).
• Part III, transitional and final provisions (Articles 364 to 368). Among other things, it contains the list of repealed provisions and the rule on the date of application.

The rules remain largely those in force today

The exercise is mainly one of reorganisation. According to FiscoOggi, the online journal of the Agenzia delle Entrate, many provisions already in force were incorporated into Part I without substantive changes, through a systematic arrangement and updating of the rules; there are, however, some new features.

A concrete example is the time limits for assessment. Article 293 brings together Article 43 of Presidential Decree No. 600/1973 and Article 57 of Presidential Decree No. 633/1972 without changing their length: the assessment notice must be served, on pain of forfeiture, by 31 December of the fifth year following the year in which the return was filed; where no return was filed or the return was null and void, by 31 December of the seventh year following the year in which the return should have been filed.

The consolidated Act also contains a cross-reference clause (Article 367, paragraph 3): unless otherwise provided, and except where provisions are repealed because they are incompatible, references in laws, regulations, decrees or other measures to expressly repealed provisions are to be read as references to the corresponding provisions of the consolidated Act. To apply it to a specific provision, it must be checked that the provision referred to is among those repealed and which provision corresponds to it.

The most visible change: the numbering

From 1 January 2027, tax notices, communications and pleadings will have to refer to the articles of the consolidated Act. Some powers, so far governed by separate provisions for income taxes and for VAT, are brought together in a single article. The correspondences below are shown in the heading of each article of the consolidated Act, as consulted on Normattiva:

For other provisions it is best not to rely on memory: the correspondence must be checked case by case. Care is also needed for provisions used every day, such as those on the deadlines for filing returns and on supplementary returns.

Amendments already made to the consolidated Act

The consolidated Act does not yet apply, but it has already been amended. Article 22 of Legislative Decree No. 148 of 7 August 2026 (Official Gazette No. 185 of 11 August 2026) inserted, both into Article 43 of Presidential Decree No. 600/1973 and into Article 293 of the consolidated Act, a rule for negative components of business income with multi-year effect, excluding those relating to non-existent transactions: the assessment period runs from the return for the tax period in which a portion was deducted for the first time. For depreciation and multi-year expenses, the rule applies to irregularities that could be detected when the asset was purchased or the expense incurred, and it applies to goods and services purchased from the tax period in progress on 31 December 2027.

Article 24 of the same decree added Article 252-bis to the consolidated Act, on assessments based on uneconomic transactions (antieconomicità): for income tax and IRAP (regional tax on productive activities) purposes, a gap between the agreed price and the market value may indicate an understatement of income or that a cost lacks the required connection with the business (inerenza) only if it is accompanied by other serious, precise and consistent evidence, or if the gap is manifest and significant.

In addition, on 13 October 2026 the Council of Ministers gave preliminary approval to a coordinating and corrective legislative decree for the eight consolidated Acts, which updates statutory references, corrects errors, completes the transposition of provisions in force and adjusts some amendments made by Legislative Decrees No. 141 and No. 148 of 2026. The decree has not yet completed its legislative process and may amend individual articles.

A tool to find your way

TrovaTU, an application available on the website of the Department of Finance, starts from the details of the current provision (year, number and, optionally, article and paragraph), shows where the provision now sits in the new consolidated Acts and allows the text in force to be compared with the text applicable from 2027. The Department states that TrovaTU is not a legislative database: it is a useful aid, to be used together with the official text, and the correspondences may change with the corrective decree.

What to do in practice

1. Until 31 December 2026 the current provisions apply. For audits, assessments by agreement and assessments straddling 1 January 2027, it is advisable to check case by case which text applies.
2. Get used to the new language of tax notices. From 2027 an invitation to appear (invito a comparire), a notice of the outcome of a formal review or an assessment notice may refer to articles that mean nothing to the reader today. Before evaluating a notice, the original provision should be identified; the heading of the consolidated Act article gives it.
3. Update templates and procedures. Engagement letters, applications, briefs, appeals, checklists and software that cite Presidential Decree No. 600/1973, Presidential Decree No. 633/1972 or the decree on assessment by agreement will need to be revised. The same applies to references to the rules on tax litigation and on penalties, which from 2027 are found in their respective consolidated Acts.
4. Follow the corrective decree. Checks carried out today should be repeated once the corrective decree has been finally approved and, in any event, before each document is drafted.

For individuals and businesses, the reorganisation does not, in most cases, change the substance of their dealings with the tax authorities. The changes must, however, be identified by comparing the consolidated Act with today’s provisions, and for some time reading tax notices will require a table of correspondences close at hand.

Sources

Legislative Decree No. 141 of 5 August 2026 (Official Gazette No. 181 of 6 August 2026, ordinary supplement No. 28), annexed consolidated Act, Articles 159, 161, 243, 245, 252-bis, 293, 345 to 363, 367 and 368 (text in force on 24 October 2026 and text applicable from 1 January 2027)

Legislative Decree No. 148 of 7 August 2026 (Official Gazette No. 185 of 11 August 2026, ordinary supplement No. 30), Articles 22 and 24

Law No. 111 of 9 August 2023, Article 21; Legislative Decrees No. 173/2024, 174/2024, 175/2024, 33/2025, 123/2025, 10/2026 and 117/2026, articles on the date of application

Council of Ministers, press release No. 192 of 13 October 2026

FiscoOggi, 7 August and 7 September 2026, and Department of Finance, TrovaTU information page