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Tax Observatory · Guide · July 2026

Concordato preventivo biennale (the two-year advance tax agreement): how it works and who benefits

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D.Lgs. 13/2024 — Concordato preventivo biennale (CPB): a practical guide

The concordato preventivo biennale allows VAT-registered persons and businesses to agree their taxable income with the tax authorities two years in advance: once the Agenzia delle Entrate proposal has been accepted, taxes and social security contributions are computed on the agreed income, irrespective of what is actually earned over the two years.

Who may join: taxpayers subject to the ISA reliability indices and, under rules of their own, those on the regime forfettario (Italian flat-rate scheme). Grounds for exclusion remain, among them substantial unsettled tax debts and unfiled returns.

The advantages: certainty as to the tax burden, exclusion from analytical and presumptive assessments and, for those who improve their ISA score, an enhanced rewards regime. Actual income exceeding the agreed figure is not taxed.

The risks: if actual income falls below the agreed figure, tax remains due on the agreed figure; the decision to join must therefore rest on realistic forecasts of turnover and margins.

The deadline: for the current two-year period the election must be completed by 31 October. The firm runs a cost-benefit simulation comparing the Agenzia delle Entrate proposal against the forecast of actual income, before you sign.

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