Tax Observatory › Tax audits › 2023 revenue out of line with e-invoices and daily takings: the Italian Revenue Agency’s letters and how to respond

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

The Italian Revenue Agency is comparing 2023 electronic invoices and electronically transmitted daily takings with the revenue reported in the 2024 income tax returns. Before correcting the return, it is essential to establish whether the difference is real or only apparent.

Under a measure dated 5 October 2026, the Italian Revenue Agency (Agenzia delle entrate) has begun sending letters, known as compliance letters, by certified email (PEC). They go to businesses whose 2023 electronic invoices and electronically transmitted daily takings (corrispettivi) are not reflected, in whole or in part, in the revenue reported in their 2024 income tax return (modello Redditi 2024). The letter is not an assessment notice and does not demand payment: it reports an anomaly and offers two courses of action. If the difference can be explained, the explanation is submitted to the Agency together with the supporting documents. If revenue was in fact omitted, the position is regularised by filing a supplementary return (dichiarazione integrativa) and using ravvedimento operoso, the voluntary correction procedure with reduced penalties. Ignoring the letter is inadvisable: the data are also available to the Guardia di Finanza, Italy’s tax and financial police.

What the measure of 5 October 2026 provides

The measure of the Director of the Italian Revenue Agency of 5 October 2026, ref. No. 271072/2026, implements Article 1(634) to (636) of Law No. 190 of 23 December 2014. These provisions allow the Agency to make the information in its possession available to taxpayers, so that they can correct errors and omissions on their own initiative. The Agency matches the data on electronic invoices issued and on daily takings electronically stored and transmitted (Legislative Decree No. 127 of 5 August 2015) against the business income reported for tax year 2023 in section RF (ordinary accounting), section RG (simplified accounting) or section LM (flat-rate regime (regime forfetario) or regime di vantaggio for young entrepreneurs) of the 2024 income tax return.

The check therefore covers business income only, and so applies to sole proprietorships, partnerships and companies, including businesses under the flat-rate regime. Self-employed professionals are outside its scope. This applies both to those under the ordinary or simplified regime, who report their fees in section RE, and to those under the flat-rate regime, who also complete section LM, but to report self-employment income.

How the letter is delivered and what it contains

The letter is sent exclusively to the taxpayer’s digital domicile, that is, the certified email address recorded in the public registers (INI-PEC or the Business Register, registro delle imprese). It can also be viewed in the taxpayer’s online tax file (Cassetto fiscale), in the section “L’Agenzia scrive” (“The Agency writes”), and on the “Fatture e Corrispettivi” (e-invoices and daily takings) portal, which holds the detailed information. The letter sets out: the taxpayer’s tax code and name or business name; the identification number, the document code and the tax year; the date and electronic filing reference of the return filed for 2023; how to request clarification or report information unknown to the Agency; and how to regularise the position.

Replies cannot be sent to the certified email address from which the letter is sent. The taxpayer replies in the manner set out in the letter and may do so through their accountant or another authorised intermediary. The measure sets no time limit for replying: in practice, the limit is the deadline by which the Agency may serve an assessment notice.

First check: is the difference real or only apparent?

The first step is a reconciliation: the total of the electronic invoices and daily takings for 2023 must be compared, item by item, with the revenue reported in the return. A discrepancy is not always an error. The most common cases of a merely apparent difference are the following.

Accrual basis. For businesses keeping ordinary accounts, revenue is allocated to tax years under Article 109 of the Consolidated Income Tax Act (TUIR, Presidential Decree No. 917 of 22 December 1986): movable goods are deemed sold on delivery or dispatch, and services on the date of completion. An invoice for an advance payment issued in 2023 for a service completed in 2024, or a deferred invoice issued in January 2023 for goods delivered in December 2022, does not form part of 2023 revenue.

Cash basis. Under simplified accounting, revenue is taxable when received (Article 66 of the TUIR), unless the business has opted for the recording-date method (Article 18(5) of Presidential Decree No. 600 of 29 September 1973); under the flat-rate regime, receipt is always the criterion (Article 1(64) of Law No. 190 of 2014). Without that option, an invoice issued in 2023 and paid in 2024 is 2024 revenue.

Sales of business assets. The sale of a machine or a vehicle is invoiced at the full price, but only the capital gain is taxable (Article 86 of the TUIR), and it is reported on a different line from revenue.

Credit notes and documents that are not revenue. Credit notes (downward adjustment notes) reduce turnover. Self-invoices (autofatture) and invoice integrations issued under the reverse charge mechanism, self-invoices for gifts to customers and sums advanced in the name and on behalf of the customer (Article 15 of Presidential Decree No. 633 of 26 October 1972) pass through the Exchange System (SdI) but are not business revenue. The position is different for goods used for the personal or family consumption of the business owner or for purposes unrelated to the business, or assigned to shareholders or partners: their normal value is revenue (Article 85(2) of the TUIR) and must be reported.

Double counting and VAT. In retail trade, the same sale may appear both in the daily takings and in an invoice issued at the customer’s request. Moreover, daily takings are collected inclusive of VAT, whereas revenue is reported net of the VAT included in them, separated out under Article 27 of Presidential Decree No. 633 of 1972. The reconciliation must eliminate any double counting and compare like with like, that is, the taxable amounts net of VAT.

If the reconciliation explains the difference, a reconciliation statement is sent to the Agency together with the supporting documents (contracts, transport documents, progress reports, fixed asset register, ledger accounts), and the receipt is kept.

If revenue was in fact omitted: supplementary return and ravvedimento operoso

If the check shows that revenue was actually left out, a supplementary 2024 income tax return must be filed, together with a supplementary 2024 IRAP return where due (Article 2(8) of Presidential Decree No. 322 of 22 July 1998), and the synthetic indices of tax reliability (ISA) form updated where necessary. The additional tax, statutory interest and the reduced penalty are then paid using form F24. In partnerships and tax-transparent companies, supplementary returns must also be filed by the partners or shareholders to whom the additional income is attributed. For sole proprietors and partners of partnerships who are enrolled in the INPS schemes for artisans and traders, the additional income also affects the social security contributions due on income above the minimum contribution base (minimale). Under the flat-rate regime, the additional tax is the substitute tax, and IRAP is not due.

The letter does not preclude ravvedimento operoso. Article 13(1-ter) of Legislative Decree No. 472 of 18 December 1997 excludes it only once notices determining the tax due (atti di liquidazione) or assessment notices have been served, including the notices of irregularities and of the outcome of formal checks provided for in Articles 36-bis and 36-ter of Presidential Decree No. 600 of 1973 and Article 54-bis of Presidential Decree No. 633 of 1972. Nor does the letter change the amount of the reduction, which depends on the time elapsed since the infringement and, where applicable, on the service of a tax audit report or a draft notice.

For infringements committed on or after 1 September 2024, the penalty for an inaccurate return is 70% of the additional tax, with a minimum of 150 euro (Article 1(2) of Legislative Decree No. 471 of 18 December 1997, as amended by Legislative Decree No. 87 of 14 June 2024). At the date of publication, the penalty is reduced to one seventh (Article 13(1), point (b-bis), of Legislative Decree No. 472 of 1997), i.e. 10% of the additional tax (with a minimum of 21.43 euro, one seventh of 150): on 1,000 euro of additional tax, the penalty is 100 euro, in addition to the tax itself and statutory interest. The same penalty for an inaccurate return also applies to IRAP, which is calculated on the value of production.

For the same infringements, the base penalty may fall to 50%, that is, double the 25% penalty laid down in Article 13(1) of Legislative Decree No. 471 of 1997. This applies where the infringement comes to light through a supplementary return filed before the taxpayer has formal knowledge of any on-site visit, inspection or audit, or of the start of any administrative assessment activity (Article 1(2-bis) of Legislative Decree No. 471 of 1997). With ravvedimento operoso, the penalty would then be 71.43 euro for every 1,000 euro of additional tax. Whether this rate remains available after receipt of the Agency’s letter has not been clarified: as a precaution, it is advisable to calculate ravvedimento operoso on the basis of the 70% penalty and to review the case with a tax adviser.

For returns filed before 1 September 2024, the previous regime may apply, with a minimum penalty of 90%. Under that regime, the penalty is reduced to one seventh if ravvedimento operoso is made by the filing deadline for the return for tax year 2025, which this year falls on Monday 2 November 2026, and to one sixth thereafter: on 1,000 euro of additional tax, 128.57 euro or 150 euro respectively. Official guidance has not yet addressed the point at which the infringement is deemed committed, and therefore which regime applies: the filing date, which is stated in the letter itself, must be checked in each case.

Time limits and precautions

The Agency may serve the assessment notice for 2023, for both income taxes and VAT, until 31 December 2029 (Article 43 of Presidential Decree No. 600 of 1973 and Article 57 of Presidential Decree No. 633 of 1972); a supplementary return may be filed within the same time limit. For businesses under the flat-rate regime that issued only electronic invoices in 2023, the time limit for income taxes is shortened by one year, to 31 December 2028 (Article 1(74) of Law No. 190 of 2014, in the version applicable up to tax year 2025). It is nonetheless advisable to regularise promptly. Ravvedimento operoso remains available until a notice determining the tax due or an assessment notice is served, including the notices of irregularities and of the outcome of formal checks provided for in Articles 36-bis and 36-ter of Presidential Decree No. 600 of 1973 and Article 54-bis of Presidential Decree No. 633 of 1972, and every month of delay adds interest and leaves the risk of an audit open.

Businesses that entered into the two-year advance tax agreement (concordato preventivo biennale) for 2024 and 2025 should carefully assess the consequences. Article 22 of Legislative Decree No. 13 of 12 February 2024, in the version applicable to that two-year period, provides for forfeiture of the agreement where an assessment reveals, in the years covered by the agreement or in the preceding year (that is, 2023), undeclared income items (attività non dichiarate), or reported expense items (passività) that prove to be non-existent or non-deductible, in an amount exceeding 30% of reported revenue. It also provides for forfeiture where a supplementary return results in income or a value of production different from the figures on which the proposal was accepted. The Agency has not clarified whether a supplementary return for 2023, the year on whose data the proposal was built, falls within this second case: the matter must be assessed case by case before the supplementary return is filed.

Where an invoice was issued but the transaction was also omitted from the periodic VAT settlement or from the annual VAT return, the review must be extended to VAT, which is governed by its own rules.

In practice

• Check the certified email inbox and the “L’Agenzia scrive” section of the Cassetto fiscale without delay, and make sure that the business’s certified email address (digital domicile) is active and that the mailbox is not full.
• Reconcile the 2023 electronic invoices and daily takings with the revenue reported in sections RF, RG or LM, taking into account the accrual or cash basis, credit notes, sales of business assets, documents that are not revenue, double counting and the VAT included in daily takings.
• If the difference is justified, reply in the manner set out in the letter, attaching the reconciliation statement and the supporting documents.
• If revenue was in fact omitted, file supplementary 2024 income tax and IRAP returns and pay the tax, interest and reduced penalty, after checking the filing date of the original return (for returns filed before 1 September 2024, the deadline of 2 November 2026 is relevant), the partners’ obligation to file supplementary returns and the effects on any two-year advance tax agreement.
• Keep the letter, the reconciliation statement, the 2023 data extracts, the filing receipts and the F24 payment receipts until the assessment time limits have expired.

Frequently asked questions

Is the Agency’s letter a tax assessment?

No. It is a letter reporting a possible anomaly and inviting the taxpayer to explain or correct it. It is not an act imposing tax (atto impositivo) and it cannot be challenged before the tax court: the time limit for an appeal runs only from the service of any subsequent assessment notice. It does not preclude ravvedimento operoso.

What is the deadline for replying?

The measure sets no time limit. However, the Agency may serve an assessment notice for 2023 at any time until 31 December 2029 (31 December 2028, for income taxes only, for businesses under the flat-rate regime that issued only electronic invoices). Once such a notice is served, ravvedimento operoso is no longer available, so it is advisable to act straight away.

I am a self-employed professional: can I receive this letter?

According to the measure, no: the exercise concerns only business income reported in sections RF, RG and LM; self-employed professionals under the flat-rate regime are excluded even though they complete section LM. Other checks on professional fees nonetheless remain possible.

Sources

Measure of the Director of the Italian Revenue Agency of 5 October 2026, ref. No. 271072/2026.

Article 1(64), (74) and (634) to (636) of Law No. 190 of 23 December 2014; Article 21 of Legislative Decree No. 148 of 7 August 2026.

Articles 1 and 2 of Legislative Decree No. 127 of 5 August 2015.

Articles 66, 85, 86 and 109 of Presidential Decree No. 917 of 22 December 1986 (TUIR).

Articles 15, 27, 54-bis and 57 of Presidential Decree No. 633 of 26 October 1972; Articles 18(5), 36-bis, 36-ter and 43 of Presidential Decree No. 600 of 29 September 1973.

Article 2(8) of Presidential Decree No. 322 of 22 July 1998.

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

Article 22 of Legislative Decree No. 13 of 12 February 2024.