The Observatory, topic by topic.

The Tax Observatory archive, organised by topic: judgments, administrative guidance and legislative developments selected and rewritten in plain language by the firm. The archive grows every week.

Assessment, collection and litigation

Tax debts and over-indebtedness procedures in Italy: what Circular 9/E tells tax offices– October 2026

Italy’s consolidated Act on tax compliance and assessment: new article numbers from 2027 for rules that are largely unchanged– October 2026

Overdue tax debts above €50,000: when the F24 offset ban applies and how to lift it– October 2026

E-invoices and unpaid payment notices: how Italy’s collection agency identifies receivables to attach in the hands of customers– October 2026

Does an amending return in the taxpayer’s favour, filed after the notice of irregularity, save you from the collection notice?– September 2026

Rottamazione-quinquies (tax debt settlement scheme): no grace period for the second instalment due on 30 September– September 2026

Accertamento con adesione and conciliazione do not fix the evaded tax: when the criminal court may redetermine it– September 2026

Settling municipal and regional payment notices in Italy: applications from 16 October to 15 December 2026– September 2026

Partnerships (società di persone): mandatory joinder (litisconsorzio) also applies to VAT– September 2026

Italian flat-rate taxpayers: the tax authorities once again have five years, as the reduction in the assessment period is abolished– September 2026

Omitted VAT return: the Agenzia computes the tax without an assessment– August 2026

Partial autotutela (self-correction by the tax office): is it a fresh, separately challengeable assessment?– August 2026

Unpaid VAT: does an instalment plan rule out the offence?– August 2026

Company struck off: who can challenge the tax assessment after five years?– August 2026

Service of a tax demand: specific challenge and proper reasons– August 2026

Shareholder loans and the presumption of unrecorded revenue– August 2026

Assessment signed before the sixty-day period from the pvc (tax audit report): unlawful– August 2026

Depreciation and amortisation: the assessment deadline runs from the first year– August 2026

Sale of a business in fraud of the tax authorities: unlimited liability for the buyer– July 2026

Reconstructing revenue: the limits of the analytical-inductive assessment– July 2026

Parallel books: when informal records become evidence– July 2026

Composizione negoziata (negotiated settlement): handling tax debts– July 2026

The cassetto fiscale (online tax account): more documents online and tracked service of notices– July 2026

«Radar» assessments: data matching and the taxpayer’s safeguards– July 2026

Rottamazione-quinquies: choosing which demands to settle with ContiTu– July 2026

Service of a tax demand valid without the second registered letter– July 2026

Summer tax suspensions 2026: payments, informal notices, assessments and tax litigation– July 2026

Companies, accounts and reorganisations

Reverse merger after an acquisition: the Italian Revenue Agency allows the acquisition vehicle’s losses to be carried forward in three cases– October 2026

Contributing holding company shares to an Italian simple partnership: no controlled realisation, tax on normal value– September 2026

Carried interest: when the manager’s return is investment income or other income– August 2026

Capital gains: no more spreading on operating assets from 2026– July 2026

Static holding companies and retained dividends: the line between a lawful choice and abuse– July 2026

Judicial liquidation: tax debts and the public prosecutor’s initiative– July 2026

The società benefit (benefit corporation): incorporation, governance and impact report– July 2026

The new OIC 5: the criteria for liquidation accounts– July 2026

A first statutory audit engagement: where the compliance work starts– July 2026

Off-the-books profits of companies: the Supreme Court widens the presumption of distribution to shareholders– July 2026

Contributing shareholdings to equity: when the controlled realisation regime of art. 177 applies– July 2026

Direct taxes and tax returns

Occasional self-employment in Italy: the €5,000 threshold is not a tax exemption– October 2026

Form 770/2026: file by Monday 2 November, and what you risk if you miss it– October 2026

Filing the Italian tax return late: until 1 February 2027 it costs 25 euro; after that the return counts as not filed– September 2026

Second IRPEF payment on account for 2026: with the rate cut to 33 per cent, the historical method may lead to overpaying– September 2026

Business travel: no traceable payment, no deduction– September 2026

Errors in a 730 return already filed: how to correct them, and by when– September 2026

DURF: what actually goes into the 10 per cent calculation– September 2026

Company cars in mixed business and private use: the flat-rate regime returns for used cars too, and two increases are introduced– September 2026

Two-year preventive agreement 2026-2027: the deadline moves to 31 October, and renewals follow new rules– September 2026

Short-term rentals: the entrepreneurship threshold drops to two properties– August 2026

IRAP and professional partnerships: the tax is not automatic– July 2026

Non-operating companies (società di comodo) in the 2026 REDDITI return– July 2026

The new consolidated income tax act– July 2026

Full carry-forward of losses: when a company really is running a new business– July 2026

VAT and compliance

2023 revenue out of line with e-invoices and daily takings: the Italian Revenue Agency’s letters and how to respond– October 2026

Stamp duty on electronic invoices: List B can be corrected until 10 September– September 2026

Second-quarter VAT settlement return due by 30 September: filing late within 15 days halves the penalty– September 2026

VAT paid in another EU Member State in 2025: refund applications are due by 30 September– September 2026

Retention of title (riserva di proprietà): taxed on delivery or on final payment?– September 2026

Daily takings by software solution: twelve hours without a connection and the till stops– August 2026

POS terminals and electronic cash registers: the 5 per cent tolerance does not cover failure to link– August 2026

Input VAT: more time, and a new rule for year-end invoices– August 2026

Electronic retail receipts: what the omnibus decree actually says– August 2026

Property and individuals

Ongoing leases in Italy: subsequent years, extension, assignment and termination within 30 days– October 2026

Rent arrears after eviction for non-payment: how they are taxed– July 2026

Sale of building land by private individuals: the capital gain and deductible costs– July 2026

European taxation

Digital VAT reporting: recapitulative statements end on 1 July 2030– August 2026

Call-off stock: last dispatch on 30 June 2028, the regime closes in 2029– August 2026

Italy’s €2 charge on non-EU parcels: third postponement, now to 1 December 2026– September 2026

EU e-commerce: how the EUR 10,000 place-of-supply threshold changes in 2027– August 2026

Excise duties: the guarantee waiver gives way to SOAC status– August 2026

CBAM: the 50-tonne threshold and the new monitoring function in the register– August 2026

Origin of goods: whoever declares it must be able to prove it– August 2026

The ViDA package: e-invoicing and digital reporting in EU VAT– July 2026

DAC8: automatic exchange of information on crypto-assets– July 2026

CBAM in its definitive period: the carbon border mechanism and importers’ obligations– July 2026

Employment and social security

Italian fringe benefits in 2026: the €1,000 and €2,000 thresholds and the checks to make before year-end– October 2026

St Francis’s Day fell on a Sunday: who is entitled to the extra amount in the October payslip– October 2026

Italian sickness benefit: the day before the certificate counts, even without a home visit– September 2026

INPS contributions: from 16 September, late payment costs 8.15 per cent a year and an instalment arrangement 4.65– September 2026

Sports volunteers: the reimbursement is not income, but it eats into the €15,000 allowance– August 2026

The INPS Guarantee Fund: unpaid TFR and final wages where the employer is insolvent– August 2026

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