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Tax and returns

The new Testo unico delle imposte sui redditi (consolidated income tax act)

As Italian tax legislation is reorganised, the recodification of the TUIR is taking shape: the same substance in a tidier structure. What to watch so the new numbering does not catch you out.

22 July 2026By Studio Ponchio3 min read

The reorganisation launched by the enabling act for tax reform continues with the drafting of consolidated acts for each area. On direct taxes, the aim is to bring today’s layered provisions back into a single coherent body of law without, in principle, changing the substance of the rules.

What changes (and what does not)

The recodification works essentially at the level of structure: merging provisions, formal coordination, repealing what has been superseded. For the taxpayer the most immediate practical consequence is the renumbering of articles and paragraphs: familiar references (from the business-relevance test for costs to the categories of income) have to be re-read against the new framework.

The practical safeguard

Until everything has settled, it is prudent to cite both the new location and the former provision in filings and submissions, to avoid misunderstandings during an audit or in litigation. The firm will progressively update its guides and forms to the recodified references.

Sources
  • The enabling act for tax reform and the implementing decrees on reorganisation (consolidated acts).
  • TUIR – d.P.R. 22 December 1986, no. 917, text in force on Normattiva.
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