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Tax ObservatoryEmployment and sport › Company cars in mixed business and private use: the flat-rate regime returns for used cars too, and two increases arrive
Employment and sport

Company cars in mixed business and private use: the flat-rate regime returns for used cars too, and two increases arrive

Article 2 of Legislative Decree No. 148/2026 has rewritten Article 51(4)(a) of the TUIR (the Italian Income Tax Code): the new-registration requirement and the contract date both fall away, the value increases by 50 per cent after 31 December of the fifth year following the year of first registration and by 5 per cent where there are accessories not included in the ACI tables. The new rules apply from tax period 2026 and, for some vehicles, already from 2025.

16 September 2026By Studio Ponchio49 min read

Anyone with a company car in use must redo the calculation. Article 2 of Legislative Decree No. 148 of 7 August 2026, published in Official Gazette No. 185 of 11 August 2026, Supplement No. 30, and in force from 12 August 2026, has entirely replaced letter a) of paragraph 4 of Article 51 of the TUIR: the provision that establishes how much the vehicle granted for mixed business and private use is worth on the payslip. Two conditions that in 2025 restricted the flat-rate criterion have fallen away — the new-registration requirement and the date of signature of the contract — and two increases have appeared that were not there before: 50 per cent for vehicles beyond the fifth year from first registration and 5 per cent for accessories not valued in the ACI tables. The new provisions apply from tax period 2026, but they also reach some of the vehicles granted in 2025. A withholding agent who does not review the calculation before the year-end tax adjustment exposes both itself and the employee to a recalculation with penalties.

What the provision now says

The version of letter a) currently in force provides that for the motor vehicles indicated in Article 54(1)(a), (c) and (m) of the Italian Highway Code — cars, motor vehicles for mixed transport and motor caravans — for motorcycles and for mopeds granted for mixed business and private use, 50 per cent of the amount corresponding to a notional mileage of 15,000 kilometres is taken, calculated on the cost per kilometre of operation obtainable from the national tables that the Automobile Club d’Italia prepares by 30 November of each year and communicates to the Ministry of Economy and Finance, which publishes them by 31 December with effect from the following tax period. The value is taken “net of any sums withheld from the employee in connection with the granting of the vehicle, including those relating to accessories and fittings”.

The percentage “is reduced to 10 per cent for battery-powered vehicles with exclusively electric traction and to 20 per cent for plug-in hybrid electric vehicles”. The two increases follow. The first: “The values determined under the first and second sentences are increased by 50 per cent after 31 December of the fifth year following the year of first registration”. The second: “Where there are accessories or fittings not valued in the tables referred to in the first sentence and not directly purchased by the worker, the value, determined under the first, second and third sentences, is increased by 5 per cent”.

The increase for age applies to the values of the first and second sentences, that is both to the ordinary rate of 50 per cent and to the reduced rates of 10 and 20 per cent: even an electric car, if it has passed the fifth year, bears the increase. The increase for accessories is calculated on the value already determined “under the first, second and third sentences”, therefore after any increase for age: the two increases apply in sequence and not by addition, and the overall factor is 1.575, not 1.55. The reference to the third sentence, within the fourth, is what resolves the question of cumulation. The reduced percentages are available only to battery-electric and plug-in hybrid vehicles: non-rechargeable hybrids remain at 50 per cent. Lastly, the scope is closed: a vehicle that does not fall among those listed — the lorry registered under letter d), the vehicle for special use, the bus — does not qualify for the flat-rate criterion under any of the regimes, and the benefit for the employee is quantified at the open market value under paragraph 3. On a mixed fleet this is the first check to be made.

What has changed compared with 2025

In 2025 letter a) concerned motor vehicles, motorcycles and mopeds “newly registered, granted for mixed business and private use under contracts entered into from 1 January 2025”, with the percentages of 50, 10 and 20 per cent. The percentages are therefore the same: the corrective decree did not alter the base rates. The two access conditions have fallen away.

The first was the requirement that the vehicle be newly registered, and it was the most problematic. A vehicle already registered — a used car purchased by the company, a vehicle returned at the end of a hire contract, a car already in the fleet — did not meet the condition and could not be valued under the flat-rate regime. The general rule of paragraph 3 of Article 51 then remained, that is the open market value of the asset, which for a car in mixed business and private use is a criterion whose application is anything but straightforward and, as a rule, more burdensome. Under the new wording the reference to new registration is gone: the flat-rate criterion is once again applicable to the vehicle as such, regardless of when it was registered.

The second condition that fell away is the contract date. The 2025 text tied the flat-rate regime to contracts entered into from 1 January 2025; today letter a) contains no reference to the date of signature, and the question of which vehicles follow which regime is resolved no longer by the provision itself, but by the transitional provisions of Article 2 of Legislative Decree No. 148/2026, by the transitional rules of the 2025 Budget Law and by the safeguard clause in Article 1(633) of Law No. 160/2019.

The regimes coexisting in 2026

In 2026 there is no single rule. Three sets of rules coexist, and the last also reaches part of 2025, a year to which a separate section is devoted. Establishing which group each vehicle in the fleet falls into is the first compliance step, and it is not an operation that can be done from memory: for each vehicle one needs the date of first registration, the date of delivery to the employee, the date of signature of the assignment contract and — for 2025 vehicles — the date of the order. Circular No. 10/E of 2025 requires that registration, signature of the contract and delivery all fall together within the reference window; for the purposes of paragraph 48-bis alone, the “granting for mixed business and private use” must be read as delivery, because that paragraph does not mention signature.

Vehicles under a contract entered into by 30 June 2020

For these vehicles the single flat rate of 30 per cent still applies, with no reference to emissions. This is provided by Article 1(633) of Law No. 160 of 27 December 2019: “The application of the rules laid down in Article 51(4)(a) of the aforementioned consolidated text referred to in Presidential Decree No. 917 of 22 December 1986, as it stood on 31 December 2019, shall remain in place for vehicles granted for mixed business and private use under contracts entered into by 30 June 2020”. That text took “30 per cent of the amount corresponding to a notional mileage of 15,000 kilometres”, also calculated on the ACI tables and also “net of any amounts withheld from the employee”, but without carbon dioxide bands, without a new-registration requirement and without increases.

Two details matter in practice. Paragraph 633 anchors the regime to the date of signature of the contract alone: it does not mention registration or delivery, and it dovetails without overlap with paragraph 632, which opens the emissions regime to contracts “entered into from 1 July 2020”. The boundary between the two regimes therefore runs on the date of signature, and the time window of paragraph 48-bis, which looks instead to the granting, operates within the group already selected by that criterion: the two sections remain distinct. And paragraph 633 is still in force, including in the text applying from 1 January 2027. A vehicle assigned under a contract of 2019 or of the first half of 2020 and still in use therefore continues at 30 per cent, and does not bear either the increase for age or the increase for accessories: both belong to later texts, and Article 2(4) of Legislative Decree No. 148/2026 extends the second only to the vehicles of paragraph 48-bis.

Vehicles granted for mixed business and private use from 1 July 2020 to 31 December 2024

For these vehicles the rules in letter a) as they stood on 31 December 2024 continues to apply. This is provided by Article 1(48-bis) of Law No. 207 of 30 December 2024 — introduced by Article 6(2-bis) of Decree-Law No. 19 of 28 February 2025, inserted by Conversion Law No. 60 of 24 April 2025, and then entirely replaced by Article 2(3) of Legislative Decree No. 148/2026. The 2024 text ties the percentage to carbon dioxide emissions: 25 per cent for vehicles with emissions not exceeding 60 grams per kilometre; 30 per cent above 60 and up to 160 grams; 50 per cent above 160 and up to 190 grams; 60 per cent above 190 grams.

One precondition limits the group: the text as it stood on 31 December 2024 concerned “newly registered” vehicles granted for mixed business and private use under contracts entered into from 1 July 2020, and “newly registered” meant vehicles registered from that same date. A vehicle registered before 1 July 2020 therefore never entered the flat-rate criterion linked to CO2, as Note 10 of Circular No. 10/E of 2025 expressly states. It does not follow, however, that it goes to open market value: if the assignment contract was entered into by 30 June 2020, paragraph 633 of Law No. 160/2019 applies, and therefore the 30 per cent flat rate. The general rule of paragraph 3 of Article 51, that is open market value, remains only for the residual combination — registration before 1 July 2020 and contract entered into from that date onwards — and applies with certainty up to tax period 2025.

What happens to that combination from 2026 is, by contrast, an open point, and it concerns a not insignificant number of vehicles. Paragraph 48-bis refers the preservation of the 2024 text to vehicles “granted for mixed business and private use” between 1 July 2020 and 31 December 2024, and the vehicle under discussion falls within it by date of granting: anyone who stops there concludes that the reference to the earlier text perpetuates its exclusion from the flat-rate regime, and with it open market value in 2026 as well. Anyone who observes instead that paragraph 48-bis is a safeguard clause, and that a safeguard cannot result in treatment worse than the ordinary one, concludes that the vehicle — never having entered the criterion linked to CO2 — falls from 2026 within the new letter a), which no longer imposes any registration requirement, and therefore within the 50 per cent flat rate. This article follows the second reading, which is the only one consistent with the declared purpose of the corrective decree, namely the opening of the flat-rate regime to used vehicles; no official guidance has confirmed it, and the calculation adopted must be documented in the vehicle’s file.

The regime is not, however, unlimited in time. The rewritten paragraph 48-bis preserves it “until 31 December of the fifth year following the year of first registration”; after that date “the value determined under the first sentence is increased by 50 per cent”. The increase for age, therefore, does not concern only the vehicles of the new regime: it also affects those in transition, but by effect of a clause specific to paragraph 48-bis and on the base determined with the percentages linked to CO2.

The outcome must be calculated band by band, because a paragraph 48-bis vehicle that passes the fifth year does not move to the new regime: it remains in the old one, increased. The four percentages become 37.5 per cent up to 60 grams, 45 per cent between 60 and 160, 75 per cent between 160 and 190, 90 per cent above 190. The comparison with the ordinary regime must however be made on equal conditions, because the increase for age affects that one too: for a vehicle that has passed the fifth year the term of comparison is not 50 per cent, but 75. It follows that the two lower bands remain more favourable, that the band between 160 and 190 grams is exactly level, and that only above 190 grams is the transitional regime more burdensome. The picture is reversed, and to a much greater extent, for zero- or low-emission vehicles: the 2024 text contained no percentages tied to the power source, so the battery-electric vehicle of paragraph 48-bis, which has zero emissions, falls within the band up to 60 grams and bears 25 per cent — 37.5 beyond the fifth year — against 10 under the new regime; the plug-in with type-approved emissions not exceeding 60 grams bears 25 against 20. On the vehicles the legislature intended to incentivise, therefore, remaining in the transitional regime costs up to two and a half times the new one.

On these conclusions, however, caution is required. In paragraph 1.2 of Circular No. 10/E of 2025 the Italian Revenue Agency stated, in relation to the transitional rules, that it has “the evident purpose of protecting taxpayers\x{2019} legitimate expectations” and that, therefore, “no penalising effects can follow from it” as compared with the application of the ordinary rules, recognising in that case the more favourable treatment. That passage was given in relation to a different question and before the corrective decree, and no documents of the Italian Revenue Agency appear to have been issued on the increase introduced in 2026: the principle nevertheless precludes the conclusion that the transitional regime entails a charge higher than the ordinary one, and it is an argument to be relied on in the event of a challenge.

Paragraph 48-bis also presents a textual tension that has not yet been resolved: the first sentence maintains the old regime “until 31 December of the fifth year following the year of first registration”, and the second provides that after that date the value determined “under the first sentence” is increased by 50 per cent. The reading followed here is the one that gives complete sense to both provisions; an alternative reading, which refers the cross-reference to the rules rather than to the calculation base, would lead to applying the increase to the percentages of the new regime, with more burdensome outcomes in the lower bands. No official guidance has confirmed either.

The rewritten paragraph 48-bis lastly adds a clarification that resolves a practical problem: “The provisions of the first and second sentences also apply where the vehicles referred to therein are granted for mixed business and private use to another employee”. The reassignment of the same vehicle to a different employee therefore does not cause the loss of the regime of origin. On this point the legislation has superseded, as a matter of law, the indication in paragraph 1.4 of the Italian Revenue Agency’s Circular No. 10/E of 3 July 2025, according to which the rules in force at that time applied to reassignment: that circular, at the date of publication of this article, has been neither withdrawn nor updated, and the misalignment between published guidance and the provision in force persists.

Vehicles granted for mixed business and private use in 2025

Here the dividing line is the order. Falling within paragraph 48-bis, and therefore following the CO2 emissions regime, are “vehicles ordered by employers by 31 December 2024 and granted for mixed business and private use in the year 2025”. According to Note 12 of Circular No. 10/E of 2025, reference must be made to the date of the purchase or rental order for the vehicle. For all other vehicles granted for mixed business and private use in 2025, Article 2(5) of Legislative Decree No. 148/2026 applies: the new provisions “also apply to vehicles granted for mixed business and private use in the year 2025 that do not fall among those referred to in Article 1(48-bis) of Law No. 207 of 30 December 2024, as amended by paragraph 3”.

The new paragraph 48-bis has also widened the transitional window: in the 2025 text vehicles ordered by 2024 were protected if granted for mixed business and private use from 1 January to 30 June 2025, whereas now the protection covers the whole of 2025.

The effect on 2025 is twofold. On the one hand, a used vehicle granted for mixed business and private use in 2025 — which the text then in force left outside the flat-rate regime because it was not newly registered — falls within the flat-rate criterion. On the other hand, a vehicle that in 2025 was valued under the flat-rate regime because it was newly registered remains in the new regime, which has in the meantime acquired the increase for age. The increase for accessories, by contrast, does not operate for 2025: Article 2(4) sets its effective date at 1 January 2026 and in any event preserves the conduct adopted up to 31 December 2025. The 2025 recalculation is therefore made with the factor 1.5, never with 1.575. Anyone who has already closed 2025 must check whether the calculation made then matches the one that today’s provision requires: the order date, for these vehicles, is information to be documented and kept, not reconstructed afterwards.

On this passage a margin of uncertainty remains, narrower however than it may seem. The clause preserving the conduct of employers, contained in Article 2(4), expressly covers only the values “relating to accessories or fittings”, not the entire regime; paragraph 3, which rewrote paragraph 48-bis, has no effective-date clause of its own. Paragraph 5, however, refers to paragraph 48-bis “as amended by paragraph 3”, and this indicates that the 2025 scope must be delimited on the rewritten text, with the window extended to the whole year.

There is then an aspect that must be named, because it is the first objection available against a recalculation of 2025. Article 2(5), first sentence, provides that “the provisions of paragraphs 1 and 2 apply from tax period 2026”, and the second sentence extends them to vehicles granted in 2025. The decree, however, entered into force on 12 August 2026, and Article 3(1), third sentence, of Law No. 212 of 27 July 2000 prescribes that for taxes “due, determined or settled periodically the amendments introduced apply only from the tax period following the one in progress at the date of entry into force of the provisions that introduce them”: that would be 2027. The decree contains no express derogation from the Taxpayer’s Statute — in the whole of Article 2 neither the word “derogation” nor the reference to Law No. 212/2000 appears — and the Statute does not have a rank higher than ordinary law, so that application from 2026 remains the one laid down. The divergence, however, exists, and anyone reviewing 2025 would do well to account for it in the file.

Vehicles granted for mixed business and private use from 2026

For vehicles granted from 1 January 2026 the new text applies: 50 per cent as the ordinary rate, 10 per cent for battery-electric vehicles, 20 per cent for plug-in hybrids, plus the two increases where their conditions are met. It does not matter whether the vehicle is new or used, nor when it was registered: the date of first registration is relevant only in establishing whether the 50 per cent increase has been triggered.

One exception remains, however, concerning the reassignment of the vehicle. If the vehicle granted in 2026 belongs to the group covered by paragraph 48-bis and had already been granted for mixed business and private use to another employee, the third sentence of that paragraph preserves the regime of origin, that is the one linked to emissions.

The increase for age: how it is calculated

The provision does not speak of “five years from first registration”. The text says “after 31 December of the fifth year following the year of first registration”: the term does not run from the date of registration, but from the end of the year, and is counted in whole years. A vehicle first registered in 2020 — in any month — reaches the fifth following year in 2025: the increase applies after 31 December 2025, therefore already from tax period 2026. A vehicle registered in 2021 reaches the fifth following year in 2026: the increase is triggered after 31 December 2026, that is from 2027. A vehicle registered in 2026 will not bear it before 2032.

Since the threshold falls at the end of the year and not mid-year, within any single tax period the vehicle falls entirely within the increase or entirely outside it: the problem of splitting the year into two parts with different percentages does not arise. This makes the fleet census a job done once a year, before the year-end tax adjustment, and not a month-by-month calculation — provided that the date of first registration is the true one, which is the date recorded on the registration certificate and not the year of the model.

The mechanism does, however, produce a consequence. For vehicles registered in 2020 or in earlier years, and falling within one of the two regimes after 30 June 2020, the threshold fell on 31 December 2025: the increase bears on the whole of 2026, by force of a provision published on 11 August 2026. And since the flat-rate criterion has opened to used vehicles, the group concerned does not end with the vehicles of the transitional regime — for which, moreover, only registration from 1 July 2020 onwards is relevant.

Accessories and fittings: the 5 per cent and the preservation of 2025

The second increase requires two conditions to be met together: that the accessories or fittings are not valued in the ACI tables, and that they have not been purchased directly by the worker. If either is missing, the 5 per cent does not apply. An accessory already included in the cost per kilometre of the version listed in the tables adds nothing; an accessory paid for by the worker does not constitute a benefit provided by the employer.

On this increase Article 2 of Legislative Decree No. 148/2026 has built a separate set of commencement rules. Paragraph 4 provides that “from 1 January 2026” the fourth sentence of letter a) — and only the fourth sentence, that is the 5 per cent — applies “also in relation to vehicles granted for mixed business and private use that fall among those referred to in Article 1(48-bis) of Law No. 207 of 30 December 2024”. The 5 per cent is therefore a cross-cutting rule: it also reaches vehicles that otherwise remain in the CO2 emissions regime. Anyone managing a fleet in transition cannot therefore limit themselves to maintaining the 2024 calculation: they must check the accessories also on the older vehicles.

The same paragraph 4 draws a line under the past: “The conduct adopted by employers up to 31 December 2025 concerning the methods of taxation of the values relating to accessories or fittings […] is preserved; no refund is due of any higher taxes paid”. The preservation operates in both directions and is not a benefit: anyone who up to 2025 taxed accessories in a manner that later turned out to be more burdensome has no right to restitution; anyone who taxed them more favourably is not subject to recovery.

Sums withheld from the employee

The value is taken net of the sums withheld from the employee in connection with the granting of the vehicle. The new text adds that among these are also counted those relating to accessories and fittings: the recharge of optional extras, if any, reduces the taxable base just as the recharge of the vehicle does. The clarification is consistent with the 5 per cent increase and mitigates its effect for those who charge the employee for whatever exceeds the standard equipment.

It is precisely on this point that a question of coordination with practice arises. By advance ruling response No. 233 of 9 September 2025 the Italian Revenue Agency had stated that sums withheld for optional extras not included in the ACI tables do not reduce the flat-rate value. That conclusion was given in relation to the text before the corrective decree and appears difficult to reconcile with the new wording, which expressly includes among the deductible sums those relating to accessories and fittings. The point must be treated as open.

For the withholding to be relevant it must be effective and documented: a charge provided for by the assignment contract and actually applied. The sums withheld, according to Circular No. 326/E of 23 December 1997 of the Ministry of Finance, must be computed inclusive of VAT.

Two items of official guidance delimit the scope of the reduction. By advance ruling response No. 14 of 21 January 2026 the Italian Revenue Agency accepted that a monthly withholding equal, over twelve months, to the notional value reduces the fringe benefit to zero: a fleet policy that charges the employee the entire flat-rate value is therefore practicable. A withholding equal to the notional value operates as a reduction of the taxable amount; it is any excess portion, recovered from variable pay, that must be withheld from the net amount. The withholding is therefore relevant up to the amount of that value: any excess does not benefit from the regime of paragraph 4 and does not generate a negative value to be set against other income. Moreover, only sums withheld in the same tax period are relevant. By advance ruling response No. 237 of 10 September 2025, by contrast, the Italian Revenue Agency excluded the possibility that sums charged to the employee for electricity consumed in private use may be deducted from the flat-rate value: electricity is neither an accessory nor a fitting, and on this aspect the new wording has no effect.

How it is calculated, in practice

The calculation follows a fixed sequence, and the order of the steps is not immaterial. One identifies the cost per kilometre of operation of the vehicle in the ACI tables valid for the year; multiplies it by 15,000 kilometres; applies the percentage; increases it by 50 per cent if the vehicle has passed 31 December of the fifth year following first registration; increases it by 5 per cent if the conditions on accessories are met; apportions the result to the days of actual granting for mixed business and private use; and only at that point subtracts the sums withheld from the employee in the tax period. Reversing the last two steps, in an assignment that does not cover the whole year, leads to a wrong result.

On one point, however, the letter of the provision may lead elsewhere, and this should be stated openly. The first sentence defines an amount already “net of any sums withheld from the employee in connection with the granting of the vehicle”; the third increases by 50 per cent “the values determined under the first and second sentences”; the fourth increases by 5 per cent “the value, determined under the first, second and third sentences”. Read literally, the chain applies the two increases to a value already reduced by the withholdings, not to the full value. The sequence followed here is the traditional one, consistent with the approach of Circular No. 326/E of 1997, which treats the reduction as the last step; but the difference is not negligible. On the petrol Golf beyond the fifth year, with an annual withholding of 1,200 euros, the traditional sequence gives 6,264 − 1,200 = 5,064 euros, the literal one (4,176 − 1,200) × 1.5 = 4,464 euros: six hundred euros of taxable amount. No official guidance has resolved the doubt after the corrective decree. Anyone adopting the literal reading should keep in the file the calculation and the reason supporting it.

The tables for 2026 have been published, by notice of the Italian Revenue Agency, in Official Gazette No. 297 of 23 December 2025, Supplement No. 40, and are also available in electronic format on the ACI website, distinguished by power source and separated between vehicles in production and out of production — the latter being the ones to look for in the case of a used vehicle. The columns for the annual fringe benefit are already calculated: 25, 30, 50 and 60 per cent for petrol, diesel and non-rechargeable hybrids, 10, 25 and 30 per cent for electric vehicles, 20, 25 and 30 per cent for plug-ins. The 10 and 20 per cent columns are therefore immediately usable under the new regime, and for petrol and diesel vehicles the 50 per cent column is too. One practical warning: the tables were prepared by 30 November 2025, before the corrective decree, and contain no column for the 50 per cent increase or for the 5 per cent increase. The two increases must be calculated outside the tables. It should be added that the 50 per cent column now serves two different regimes, the new ordinary rate and the band between 160 and 190 grams of the transitional regime: on the payslip the two cases must be kept distinct. The same applies to the 30 per cent column, used both for the flat rate on contracts entered into by 30 June 2020 and for the band between 60 and 160 grams of the transitional regime.

An example with real figures. For a Volkswagen Golf VIII 1.5 TSI 115CV the cost per kilometre shown in the 2026 tables is 0.5568 euros: the annual base is 0.5568 × 15,000 = 8,352 euros, and the value at 50 per cent is 4,176 euros. If the same vehicle has passed the fifth year from first registration, the value rises to 6,264 euros; if there are also accessories not valued in the tables and not purchased by the worker, it reaches 6,577.20 euros (4,176 × 1.5 × 1.05). For a Fiat 500 saloon 42 kWh electric, with a cost per kilometre of 0.3927 euros, the base is 5,890.50 euros and the value at 10 per cent is 589.05 euros. For a Golf 1.5 TSI eHybrid 204CV, with a cost per kilometre of 0.6166 euros, the base is 9,249 euros and the value at 20 per cent is 1,849.80 euros.

The comparison between the two regimes, on the same vehicle, quantifies the difference: for the petrol Golf the old 30 per cent of the intermediate band gave 2,505.60 euros, the new 50 per cent gives 4,176 euros, an increase of 1,670.40 euros of taxable income per year. On the lower values, by contrast, the calculation may come to zero by effect of the fringe benefit exemption threshold, of which more below.

The value so obtained must lastly be apportioned to the period of granting. Circular No. 326/E of 1997 specifies that the amount “must be apportioned to the period of the year during which the employee is granted mixed business and private use of the vehicle, counting the number of days for which the vehicle is assigned, irrespective of its actual use”. For an assignment from 1 April to 31 December 2026, that is 275 days, the value of the petrol Golf at 50 per cent becomes 4,176 × 275 / 365 = 3,146.30 euros. The same circular specifies two further aspects. It is irrelevant that the employee bears some of the elements of the running cost, because reference is in any event made to the total cost shown in the tables. And the two extreme cases have opposite outcomes: a vehicle granted exclusively for personal or family use is valued at the open market value under Article 9 of the TUIR, whereas use exclusively for business travel does not contribute to forming income.

Social security contributions

The notional value is not relevant only for tax purposes. The social security taxable base is aligned with the tax base by Article 12 of Law No. 153 of 30 April 1969, in the text replaced by Article 6 of Legislative Decree No. 314 of 2 September 1997: the reference to the provisions on employment income also includes paragraph 4 and the flat-rate criterion, and the list of elements excluded from the taxable base is exhaustive. The alignment, however, does not entail coincidence: differences remain as to the criteria for allocation over time and as to minimum thresholds.

The car fringe benefit is not among the exclusions, and INPS confirms this in Circular No. 156 of 30 December 2025, where it recalls that company vehicles granted for mixed business and private use “are subject to contributions (and to taxation) taking as the base a value determined on a notional basis”. That circular, however, must be used with caution: it reproduces paragraph 48-bis in the text before the corrective decree, with protection limited to vehicles granted up to 30 June 2025, and it does not take account of the two increases. At the date of publication no INPS documents subsequent to Legislative Decree No. 148/2026 appear to have been issued: the natural place for them will be the year-end adjustment circular.

Three practical warnings remain. The clause preserving conduct and the prohibition on refunds in Article 2(4) are tax provisions and do not automatically extend to the social security side. The window for the contribution adjustment is shorter than the tax one, because the adjustment is made with the December or January contribution return, and not up to 28 February; anyone planning the fleet census around the tax deadline arrives late on contributions. The last warning weighs on the decision to review 2025, because for social security purposes the recovery of the employee’s share works differently from the tax one. In the year-end adjustment it is permitted, and INPS requires the employer to withhold the difference not withheld during the year; outside that window it is not, because Article 23 of Law No. 218 of 4 April 1952 obliges an employer who has not paid within the deadlines to pay the contributions “both as to its own share and as to that of the workers”, while Article 2115, second paragraph, of the Civil Code grants it the right of recourse “in accordance with special laws”. Outside the year-end adjustment those laws do not permit it, and the settled reading therefore excludes it as against the employee. Anyone reviewing 2025 today therefore also pays the worker’s share without being able to recover it: this is a cost to be taken into account before deciding, and one more reason to complete the review within the current year’s adjustment.

The criteria for allocation over time also diverge: for tax purposes Article 51(1), second sentence, treats as received in the tax period also the values paid by 12 January of the following year — an aspect that for the car is relevant above all for the shared ceiling of the exemption threshold — whereas for social security purposes Article 12(1) of Law No. 153/1969 looks to income accrued in the reference period.

The fringe benefit exemption threshold

On the lower values there is an aspect that can radically change the outcome, and it needs to be addressed precisely. The value determined under the flat-rate criterion falls within the exemption threshold for goods supplied and services rendered provided by paragraph 3 of the same Article 51. Paragraph 4 opens with the words “for the purposes of applying paragraph 3”, the flat-rate criteria therefore determine the value precisely for that paragraph, threshold included, and Circular No. 326/E of 23 December 1997 of the Ministry of Finance specifies that that provision “is of a general character applicable without doubt also with reference to the goods indicated in the following paragraph 4”.

The ordinary threshold under paragraph 3 is 258.23 euros. Article 1(390) and (391) of Law No. 207 of 30 December 2024, by way of derogation from the first part of the third sentence of that paragraph, raise it for tax periods 2025, 2026 and 2027 to 1,000 euros, and to 2,000 euros for a worker with children who meet the conditions laid down in Article 12(2) of the TUIR, provided that the worker declares this to the employer indicating the tax code of each child.

This threshold has three characteristics not to be overlooked. The first: it is a limit, not an allowance. If it is exceeded even by one euro, the entire value contributes to forming income and not only the excess portion — paragraph 3 says so in the part that paragraph 390 has not derogated from, and the Italian Revenue Agency reiterated it in Circular No. 4/E of 16 May 2025. The second: the limit is overall, and also absorbs reimbursements of household utilities for the water service, electricity and gas, rent and mortgage interest on the main home, as well as any other good or service, including those provided by previous employers in the same tax period. The third: since for the car the annual value is known as early as January, if it is clear that the total will exceed the threshold, the withholding must be applied from the first pay period, and not from the month in which the excess materialises.

With the figures from the examples the difference is clear. The electric Fiat 500, at 589.05 euros, alone absorbs almost 60 per cent of the threshold raised to 1,000 euros, and remains below the limit even beyond the fifth year (883.58 euros) and with both increases (927.75 euros): if there are no other benefits, the taxable amount is zero. The petrol Golf, at 4,176 euros, is outside the threshold in any scenario. INPS aligns with this reading in Circular No. 156 of 30 December 2025, where it states that the value of the car in mixed business and private use “falls within the rules of Article 1(390) of Law No. 207/2024” and that exceeding the limit “entails the inclusion of the entire amount in the determination of taxable income […] and not only of the excess portion”.

Paragraph 390 has been repealed, with effect from 1 January 2027, by Article 376 of the consolidated text of the income tax laws, which has however carried its content over into Article 53(4): for 2026 the provision to be applied remains paragraph 390. For 2027 the raised limit does not cease, because the derogation covers that year too and from that date it is to be found in that provision.

Directors and other income treated as employment income

The flat-rate criterion does not concern employees only. Article 52(1) of the TUIR (the Italian Income Tax Code) provides that, for the purposes of determining income treated as employment income, the provisions on employment income apply: the text refers to “Article 48”, under the numbering in force before the reform, to be read as the current Article 51 by virtue of Article 2(3) of Legislative Decree No. 344 of 12 December 2003. The reference is unqualified and includes paragraph 4(a). A vehicle granted for mixed business and private use to a director who receives remuneration qualifying as income treated as employment income is therefore valued under the same rules, including the two increases. The exceptions are the annuities and allowances referred to in Article 47(1)(h) and (i) under the numbering of the text, now Article 50, for which Article 52 itself excludes the application of those provisions.

It should be added that the guidance on this point is long-standing: Circular No. 67/E of 6 July 2001 affirmed the principle but indicated a percentage — 30 per cent — belonging to a regime that was superseded long ago. The principle remains applicable; the percentage indicated in that document no longer is.

There is also a practical effect to be borne in mind, and on the social security side it has no remedy. If the vehicle is granted to the director without sufficient cash remuneration, the notional value generates taxable income without any corresponding cash being available from which to make the withholding. For tax purposes, Article 23 of Presidential Decree No. 600 of 29 September 1973 assists, obliging the taxpayer subject to withholding to pay the withholding agent the amount of the withholding. On the social security side, however, it does not: the contribution to the INPS separate social security scheme is split one third borne by the member and two thirds borne by the principal, but the latter is the only party obliged towards INPS, and if the cash remuneration does not allow the one-third share to be withheld, the principal pays the whole amount and retains a mere claim against the director. The solution is contractual and must be adopted when the resolution is passed: provide for cash remuneration at least sufficient to absorb the withholding and the contribution calculated on the value of the vehicle, or impose a withholding on the director in respect of the grant, which reduces the taxable value at source.

Company side: deductibility and VAT

On the corporate tax side nothing has changed: the corrective decree did not touch Article 164 of the TUIR, where the 70 per cent in letter b-bis) dates back to Article 4(72) and (73) of Law No. 92 of 28 June 2012, and the 20 per cent in letter b) to Article 1(501) of Law No. 228 of 24 December 2012. Certain rules therefore remain in place which bear recalling alongside the new calculation of the benefit. The deduction is 70 per cent “for vehicles granted for mixed business and private use to employees for the greater part of the tax period”, and according to Circular No. 48/E of 10 February 1998 half the days of the employer’s tax period plus one are required, without the use having to be continuous or refer to the same employee; if the requirement is not met, letter b) applies, with 20 per cent and the caps at acquisition cost, 18,075.99 euros for cars. Letter b-bis) does not refer to those caps. And the 70 per cent applies to the entire amount of the costs, without reducing it by the benefit taxed in the employee’s hands.

For directors, letter b-bis) does not apply, because its scope is limited to employees. On the cost of the vehicle, the relevant guidance is Circular No. 1/E of 19 January 2007, paragraph 17.2, letter B.1, according to which “the amount of the fringe benefit which contributes to forming the director’s income is deductible for the company, pursuant to Article 95 of the TUIR, up to the amount of the expenses borne by the latter”, while “any excess of the expenses borne by the company over the fringe benefit is not deductible, by reason of the new regime of non-deductibility of non-business vehicles”.

That second proposition cannot be read on its own, because it carries its own reasoning with it. The regime that justified it — the total non-deductibility of non-business vehicles introduced by Article 2(71) of Decree-Law No. 262 of 3 October 2006 — was removed a few months later by Article 15-bis(7), (8) and (9) of Decree-Law No. 81 of 2 July 2007, converted by Law No. 127 of 3 August 2007, which restored partial deduction and and made it available as from the tax period in progress on 3 October 2006. Once the premise had fallen away, the criterion in paragraph 2.1.2.1 of Circular No. 48/E of 1998 became applicable again — a criterion that paragraph 5.1 of Circular No. 47/E of 18 June 2008 declared still valid: the excess of expenses over the benefit is deductible under Article 164(1)(b), today at the rate of 20 per cent and within the cost limits laid down in that letter. This is the current solution, and it is the one adopted here; the Italian Revenue Agency has, however, never expressly corrected that passage of the 2007 circular, and in the event of a check the position must be supported by reasons.

The picture closes with two clarifications. The conclusion does not extend to a vehicle granted for the director’s exclusively personal use: for that different case, the excess over the remuneration in kind remains non-deductible, already under paragraph 2.1.2.1 of the 1998 circular. And the same 2007 circular specifies that, where the office of director falls within the institutional duties of the employment relationship, the related income is drawn into employment income and Article 164 applies in full once again to the costs of the vehicle.

For VAT purposes, Article 19-bis1(1)(c) of Presidential Decree No. 633/1972 allows a deduction “at the rate of 40 per cent” if the vehicles “are not used exclusively in the course of the business”, and paragraph (d) extends the same rate to fuel, maintenance, garaging and repairs. A full deduction remains possible on one precise condition: that the vehicle is made available to the employee “against specific consideration”, because in that case the transaction is taxable and the vehicle is deemed to be used exclusively in the course of the business. This was stated in Resolution No. 6/DPF of 20 February 2008 and confirmed by advance ruling response No. 631 of 29 December 2020. Outside that case, where the vehicle is granted without specific consideration, the deduction remains at 40 per cent and private use does not give rise to any taxable transaction: the flat-rate limitation upstream absorbs personal use downstream. These are two alternative approaches, and the choice must be made in the fleet policy before allocation, not afterwards. On the taxable base of that recharge, however, an open question remains: Article 13(3)(d) of Presidential Decree No. 633/1972 sets it at open market value where the consideration is lower, Article 14(3) refers the criteria to a ministerial decree which does not appear to have been issued, and the automatic link to the fringe benefit parameter, provided for by an earlier version of Article 14, was removed in 2009. Anyone who today takes the value of the benefit as the VAT taxable base therefore applies a criterion that has no express statutory basis.

The year-end tax adjustment and what the withholding agent risks

The moment at which the account must be closed is the year-end tax adjustment. Article 23(3) of Presidential Decree No. 600/1973 requires the withholding agent to carry it out “by 28 February of the following year” and, where the relationship ends, on the date of termination. For the 2026 tax period, 28 February 2027 falls on a Sunday, and the deadline shifts to Monday 1 March. Withholdings are paid over by the 16th day of the month following the one in which they are made: for an adjustment carried out in February, by 16 March 2027.

The company car fringe benefit poses a structural problem: it is a value, not a sum, and the withholding must be made on it without any corresponding cash being available. For this reason, the second sentence of Article 23(1) provides that where the withholding cannot be covered by payments made at the same time in cash, “the taxpayer subject to withholding is required to pay the withholding agent the amount corresponding to the withholding”. Where remuneration is insufficient, paragraph 3 allows the taxpayer subject to withholding to declare in writing that he or she intends to pay the amount, or to authorise the levy on remuneration for pay periods after the second, with interest of 0.50 per cent per month. This is not a free instalment plan: these are two standardised alternatives requiring the employee’s written initiative. That interest corresponds to 6 per cent on an annual basis, against a statutory rate of 1.60: the deferral is costly and must be explained as such to the employee.

The same paragraph 3 adds a third step, which for the car is the ordinary outcome where employment ends at the year end: the amount which at the end of the tax period has not been withheld owing to termination of the relationship or insufficiency of remuneration “must be notified to the person concerned, who must pay it by 15 January of the following year”. This is a duty of the withholding agent, not an option: anyone who stops at the two alternatives omits a notification that is due and deprives the employee of the deadline for payment.

If the calculation was wrong, the same fact is relevant for the purposes of three distinct penalty provisions. Withholdings that were not made entail the penalty of 20 per cent of the amount not withheld, laid down in Article 14 of Legislative Decree No. 471/1997, which the 2024 reform of penalties did not amend. Withholdings made but not paid over entail the penalty of 25 per cent under Article 13, reduced by half for payments made with a delay of no more than ninety days and, for delays of no more than fifteen days, further reduced to one fifteenth for each day, that is 0.8333 per cent per day. The third, and most onerous, is an inaccurate return by the withholding agent, penalised by Article 2(2) of the same decree at 70 per cent of the withholdings not paid over attributable to the difference. A comparison between 20 and 25 per cent alone therefore underestimates the exposure.

The remedy is voluntary correction under Article 13 of Legislative Decree No. 472/1997, with the penalty reduced to one ninth within ninety days of the omission, to one eighth by the deadline for filing the return for the year of the infringement and to one seventh after that deadline: on the 20 per cent for withholdings that were not made, this means 2.22, 2.5 and 2.86 per cent respectively. The reduction to one tenth under letter (a) concerns only non-payment of the tax, and therefore applies to withholdings made but not paid over. For the withholding agent, that return is the 770 form, which for 2026 is due on 31 October 2027 and, as that day falls on a Sunday, shifts to 2 November. Interest is calculated at the statutory rate day by day, set at 1.60 per cent per annum from 1 January 2026.

If the adjustment has already been closed, the single certification (Certificazione Unica) must be resubmitted in corrected form — penalty of 100 euros for each, with a maximum of 50,000 euros per withholding agent, reduced to one third and with a maximum of 20,000 euros if the corrected filing takes place within sixty days, and excluded if the correction is made within the five days following the deadline — and an amended 770 form must be filed. Here the 70 per cent for inaccuracy gives way, if the infringement emerges from an amended return filed within the deadlines in Article 43 of Presidential Decree No. 600/1973 and before the withholding agent has had formal knowledge of checks, to the penalty under Article 13(1), increased to double: today 50 per cent.

In practice: what to do now

The work to be done before the year-end adjustment is a survey, and it forms part of the ordinary administration of personnel. For each vehicle granted for mixed business and private use, the following must be recorded: the date of first registration taken from the registration certificate, the date of delivery to the employee, which, for the purposes of paragraph 48-bis, Circular No. 10/E of 2025 treats as the granting for mixed business and private use, the date of signature of the assignment contract, the date of the order for vehicles granted in 2025, the power source, the presence of accessories or fittings not included in the version listed in the tables and any sums withheld. On these seven items of information the applicable regime is decided and the calculation reconstructed. To check the exemption threshold, two further items are needed, concerning the worker and not the vehicle: whether he or she has children who meet the conditions that double the limit, and how much he or she has already received during the year in goods and services, including from previous employers.

Four checks come first. Assignment contracts entered into by 30 June 2020: if the vehicle is still in use, it remains at 30 per cent and is not subject to increases. Vehicles first registered in 2020 or earlier: in 2026 they bear the 50 per cent increase, under both subsequent regimes. Vehicles granted for mixed business and private use in 2025: they must be brought under the new regime if they had not been ordered by 31 December 2024, and this may change the calculation already made for that year. Accessories not listed in the tables must be checked on all vehicles under the two regimes subsequent to 30 June 2020, including those in transition, because from 1 January 2026 the 5 per cent applies to them in any event.

If the check requires the 2025 figures to be corrected, the route is the ordinary one of correction, and it is worth being clear about it before taking it: corrected single certification, amended 770 form, voluntary correction on withholdings that were not made and, on the social security side, a UniEmens variation flow. Outside the year-end adjustment, however, the share borne by the worker remains with the employer, and the 2025 recalculation is done with the 1.5 factor alone.

The documentation must be retained, because in the event of a check it is what supports the calculation: the assignment contract stating the mixed business and private use and any sums withheld, a copy of the registration certificate, the order document for 2025 vehicles, the list of optional extras stating who paid for them, a printout of the ACI table used and the calculation spreadsheet for the value.

From 1 January 2027, the same rule in another text

Article 2(2) of Legislative Decree No. 148/2026 has also replaced, with identical wording, Article 53(6)(a) of the consolidated text of the income tax laws approved by Legislative Decree No. 117 of 19 June 2026. The consolidated text is in force from 4 July 2026, but its provisions apply from 1 January 2027 by virtue of Article 377, from which date Articles 1 to 191 of the TUIR are repealed under Article 376(1)(e). Until 31 December 2026 the reference provision therefore remains Article 51(4)(a) of the TUIR; from 1 January 2027 the same rules are to be found in Article 53(6)(a) of the consolidated text. That repeal also covers, from the same date, Article 164, that is the provision on deductibility mentioned above. The legislature aligned the two texts at the same time: this is a useful fact for those drafting assignment contracts and fleet policies intended to last beyond the current year.

The same date also moves the procedural and penalty provisions referred to in this article. Article 23 of Presidential Decree No. 600/1973, on the year-end adjustment, is repealed by Legislative Decree No. 33 of 24 March 2025, and Legislative Decrees No. 471 and No. 472 of 1997, on penalties and voluntary correction, by Legislative Decree No. 173 of 5 November 2024: in both cases with effect from 1 January 2027, by virtue of the deferral laid down by Decree-Law No. 200 of 31 December 2025. For the 2026 tax period, which is the one dealt with here, the provisions cited remain applicable.

The same applies on the VAT side, and more starkly. The consolidated text of the legislative provisions on value added tax, approved by Legislative Decree No. 10 of 19 January 2026, applies from 1 January 2027 by virtue of Article 171 thereof; from that date Article 170(1)(a) repeals, among others, Articles 1 to 17 and 17-ter to 27 of Presidential Decree No. 633/1972, and this includes all three provisions referred to in the paragraph on deductibility and VAT: Articles 13, 14 and 19-bis1. The repeal proceeds by ranges and does not name individual articles. For 2026 nothing changes: the provisions cited continue to apply.

Frequently asked questions

I have a company car allocated in 2023: does anything change for me in 2026?

It depends on the date of first registration. If the vehicle was granted for mixed business and private use in 2023 and registered from 1 July 2020, it falls under Article 1(48-bis) of Law No. 207/2024 and follows the percentages linked to carbon dioxide emissions. If, on the other hand, registration predates that date, the vehicle never entered the emissions-linked criterion and, since the contract does not predate 1 July 2020, until 2025 it was valued at open market value. From 2026, according to the reading followed in this article, the new letter a) no longer imposes any registration requirement and brings it within the ordinary flat rate of 50 per cent, already increased for age. This is the open point set out above, and the choice must be documented. Returning to a vehicle registered from 1 July 2020: if registration took place in the second half of that year, from 2026 the value is increased by 50 per cent, because 31 December of the fifth following year has passed. From 1 January 2026, the 5 per cent increase also applies to this vehicle for accessories not valued in the ACI tables and not purchased by the worker.

My company gave me a used car in 2025: how is it taxed?

Under the flat-rate criterion of the new text, if the vehicle had not been ordered by the employer by 31 December 2024. This is provided for by Article 2(5) of Legislative Decree No. 148/2026, which extends the new provisions to vehicles granted for mixed business and private use in 2025 that are not covered by paragraph 48-bis. This is a situation to be checked, because the text in force in 2025 required the vehicle to be newly registered and for used vehicles the flat rate was not applicable: the calculation made at the time may not coincide with what the current provision requires. As to the extent of the effects on 2025, at the date of publication official guidance is lacking.

If I pay for the options myself, does the 5 per cent increase apply?

No, if the accessories were purchased directly by the worker: the provision requires, cumulatively, that they are not valued in the ACI tables and that they are not purchased directly by the worker. If, on the other hand, the purchase is made by the company and the cost is recharged with a withholding, the increase applies, but the sums withheld are deducted from the value, because the new text includes among the deductible sums also those relating to accessories and fittings. On this last point, advance ruling response No. 233 of 2025, given in relation to the previous text, stated the opposite: the coordination with the new wording has not yet been clarified.

Sources

Legislative Decree No. 148 of 7 August 2026, Article 2(1) to (5) (Official Gazette No. 185 of 11 August 2026, Supplement No. 30; in force from 12 August 2026; republished with notes in Official Gazette No. 205 of 4 September 2026, Supplement No. 33)

TUIR, Presidential Decree No. 917 of 22 December 1986, Article 51(4)(a), as it stood on 16 September 2026, on 11 August 2026 and on 31 December 2024 (Normattiva)

TUIR, Articles 52(1); 95; 164(1)(b) and (b-bis); Legislative Decree No. 344 of 12 December 2003, Article 2(3)

Law No. 160 of 27 December 2019, Article 1(632) and (633) (as it stood on 16 September 2026; Official Gazette No. 304 of 30 December 2019, Supplement No. 45); TUIR, Article 51(4)(a), as it stood on 31 December 2019

Law No. 212 of 27 July 2000, Article 3(1)

Legislative Decree No. 10 of 19 January 2026 (consolidated text on value added tax), Articles 170(1)(a) and 171 (Official Gazette No. 24 of 30 January 2026, Supplement No. 4)

Law No. 207 of 30 December 2024, Article 1(48), (48-bis), (390) and (391); Decree-Law No. 262 of 3 October 2006, Article 2(71), converted by Law No. 286 of 24 November 2006; Decree-Law No. 81 of 2 July 2007, Article 15-bis(7), (8) and (9), converted by Law No. 127 of 3 August 2007; Law No. 92 of 28 June 2012, Article 4(72) and (73); Law No. 228 of 24 December 2012, Article 1(501); Decree-Law No. 19 of 28 February 2025, Article 6(2-bis), converted by Law No. 60 of 24 April 2025

TUIR, Article 51(3), third sentence, and Article 12(2)

Legislative Decree No. 117 of 19 June 2026 (consolidated text of the income tax laws), Articles 53(6)(a), 376(1)(e) and 377 (Official Gazette No. 152 of 3 July 2026, Supplement No. 26)

Legislative Decree No. 285 of 30 April 1992, Article 54(1)(a), (c) and (m); Presidential Decree No. 633 of 26 October 1972, Articles 13(3)(d), 14(3) and 19-bis1(1)(c) and (d)

Law No. 153 of 30 April 1969, Article 12(1), (2) and (5), as replaced by Article 6 of Legislative Decree No. 314 of 2 September 1997; Legislative Decree No. 344 of 12 December 2003, Article 2(4); Law No. 218 of 4 April 1952, Article 23, first paragraph; Italian Civil Code, Article 2115, second paragraph; Law No. 335 of 8 August 1995, Article 2(26) and (30)

Presidential Decree No. 600 of 29 September 1973, Article 23(1) and (3); Legislative Decree No. 241 of 9 July 1997, Article 18; Presidential Decree No. 602 of 29 September 1973, Article 8(1)(1); Decree-Law No. 70 of 13 May 2011, Article 7(1)(h); Presidential Decree No. 322 of 22 July 1998, Article 4(6-quinquies)

Legislative Decree No. 471 of 18 December 1997, Articles 2(2), (2.1) and (2-ter), 13 and 14; Legislative Decree No. 472 of 18 December 1997, Article 13; Legislative Decree No. 87 of 14 June 2024, Article 5(1)

Legislative Decree No. 33 of 24 March 2025 and Legislative Decree No. 173 of 5 November 2024, as amended by Decree-Law No. 200 of 31 December 2025, converted by Law No. 26 of 27 February 2026 (repeals with effect from 1 January 2027)

ACI tables of cost per kilometre for 2026: notice of the Italian Revenue Agency in Official Gazette No. 297 of 23 December 2025, Supplement No. 40

Italian Revenue Agency: Circulars No. 10/E of 3 July 2025 (in particular paragraph 1.2 and note 10) and No. 4/E of 16 May 2025; Circulars No. 47/E of 18 June 2008 (paragraph 5.1), No. 1/E of 19 January 2007 (paragraph 17.2, letter B.1), No. 67/E of 6 July 2001 and No. 48/E of 10 February 1998 (paragraph 2.1.2.1); advance ruling responses No. 233 of 9 September 2025, No. 237 of 10 September 2025, No. 14 of 21 January 2026 and No. 631 of 29 December 2020

Ministry of Finance, Circular No. 326/E of 23 December 1997, paragraphs 2.3.1 and 2.3.2.1; Ministry of Economy and Finance – Department for Tax Policies, Resolution No. 6/DPF of 20 February 2008

INPS, Circular No. 156 of 30 December 2025, paragraphs 7, 7.1 and 9

Ministerial Decree of 10 December 2025 on the statutory interest rate for 2026 (Official Gazette No. 289 of 13 December 2025)

However, the regime applicable to each vehicle depends on items of fact — date of first registration, date of signature of the assignment contract, date of delivery to the employee, date of the order, fuel type, the accessories fitted, sums withheld — which the article cannot establish on the employer’s behalf, and the calculation must be redone vehicle by vehicle on the ACI table for the year of reference. At the date of publication, no official guidance from the Italian Revenue Agency appear to have been issued on Legislative Decree No. 148/2026 in relation to company cars, and the points which the article flags as such remain open: the regime from 2026 of a vehicle registered before 1 July 2020 and granted for mixed business and private use under a later contract; the extent of the effects on the 2025 tax period and the divergence with Article 3(1) of Law No. 212/2000; the order between the increases and the sums withheld in the calculation sequence; the coordination with advance ruling response No. 233 of 2025 and the VAT taxable base of the recharge. Before applying a retroactive recalculation, the documentation for the individual vehicle should be examined with one’s own adviser, bearing in mind that on the social security side the share borne by the worker, outside the year-end adjustment, remains borne by the employer.

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