Tax Observatory › Property and individuals › Short-term lets at the Lidi di Comacchio: cedolare secca, CIN and when letting becomes a business

Short-term lets at the Lidi di Comacchio: cedolare secca, CIN and when letting becomes a business

Anyone letting a second home in Lido degli Estensi, Lido di Spina, Lido delle Nazioni, Porto Garibaldi, Lido di Volano, Lido di Pomposa or Lido degli Scacchi for periods of up to thirty days can apply the cedolare secca (flat-rate tax on rental income) at 21% on one unit and at 26% on the other; from the third flat onwards the regime is lost and the activity is presumed to be a business. The CIN (codice identificativo nazionale, national identification code), the guest notification to the police, the imposta di soggiorno (tourist tax) of the Municipality of Comacchio and IMU (municipal property tax) at 1.14% still apply.

Anyone letting a second home on the Po Delta coast under contracts of up to thirty days falls within the rules on locazioni brevi (short-term lets) laid down in Article 4 of Decree-Law No. 50/2017, converted into law by Law No. 96/2017. From the 2026 tax year the regime applies only if no more than two flats are allocated to short-term letting (Article 1, paragraph 595, of Law No. 178/2020, as amended by Article 1, paragraph 17, of Law No. 199/2025; from 2027 Article 207, paragraph 4, of Legislative Decree No. 117/2026).

The cedolare secca and the two-flat threshold

A locazione breve is a lease of residential property for a period of up to thirty days, entered into by individuals outside the conduct of a business, including where linen and cleaning are provided (Article 4, paragraph 1). The cedolare secca under Article 3 of Legislative Decree No. 23/2011 (from 2027 Article 203 of Legislative Decree No. 117/2026) applies to the whole rent, without the 5% reduction, at a rate of 26%, reduced to 21% for one unit chosen in the tax return (Article 4, paragraph 2; Circular No. 10/E of 10 May 2024). Without the option, 95% of the rent is subject to IRPEF, the personal income tax (Article 37, paragraph 4-bis, of the Consolidated Income Tax Act, TUIR; from 2027 Article 39, paragraph 5, of Legislative Decree No. 117/2026).

An intermediary that collects the rent or is involved in its payment applies and certifies a 21% withholding tax on the gross amount due from the tenant, including the landlord’s commission where it is included in that amount, but excluding security deposits and contractual penalties (Article 4, paragraph 5; from 2027 Article 208, paragraph 2, of Legislative Decree No. 117/2026; guide of the Italian Revenue Agency, Agenzia delle Entrate, April 2026). It does not withhold if the payment is handled only by card issuers or payment service providers. On the unit taxed at 26% the withholding remains at 21% and the difference is paid with the balance payment (Circular No. 10/E/2024).

The two-property threshold counts the flats allocated to short-term letting, not those owned. From the third flat, the activity is presumed to be a business, which entails VAT registration, a SCIA (certified notice of commencement of activity) and taxation as business income; the cedolare is lost, but the intermediary stops withholding only once it receives the landlord’s VAT number (Revenue Agency guide). Administrative guidance has not clarified whether the presumption can be rebutted.

With EUR 9,000 of rent on a single unit at 21%, the tax, EUR 1,890, is covered by the withholding if the portal collects the rent; with two units at EUR 9,000 each it rises to EUR 4,230 (1,890 plus 2,340), against withholdings of EUR 3,780, leaving a balance of EUR 450.

Registration and tax return

Contracts of up to thirty days do not have to be registered, unless made by public deed or by authenticated private agreement (Article 2-bis of the Tariff, Part Two, of Presidential Decree No. 131/1986; from 2027 Article 3 of the Tariff, Part Two, Annex 1 to Legislative Decree No. 123/2025). They must, however, be registered if the contracts entered into in the year with the same tenant exceed thirty days in total (Circular No. 24/E of 12 October 2017, point 1). The option is exercised in the return for the year in which the rent is received (Schedule RB of the Redditi PF return or Schedule B of Form 730), indicating the unit taxed at 21% and crediting the withholdings shown in the Certificazione Unica (annual withholding certificate).

CIN, safety and Alloggiati Web

Every unit let for tourist purposes or as a short-term let must have the national identification code (CIN) issued by the Ministry of Tourism, assigned through the national database of accommodation facilities (Article 13-ter, paragraphs 1 to 3, of Decree-Law No. 145/2023, converted into law by Law No. 191/2023). In Emilia-Romagna the database is fed by ROSS 1000 and, upstream, by the notification to the SUAP (one-stop shop for business activities), without which the CIN cannot be obtained. The code has been mandatory since 2 November 2024, the sixtieth day after publication of the notice in the Official Gazette of 3 September 2024 (paragraph 15; Emilia-Romagna Region circular ref. No. 951915 of 5 September 2024). The code must be displayed outside the building, in compliance with planning and landscape constraints, and shown in every listing (paragraph 6). Combustible gas and carbon monoxide detectors are required, together with portable fire extinguishers of the type provided for by the Ministerial Decree of 3 September 2021, one for every 200 square metres or part thereof and at least one per floor (paragraph 7); under the regional circular and the ministerial FAQs, detectors are not required in a unit with no gas installation and no carbon monoxide risk.

Paragraph 9, enforced by the Municipality through the local police, penalises letting a unit without a CIN (fine of EUR 800 to EUR 8,000), failure to display the code or show it in listings (EUR 500 to EUR 5,000, with immediate removal of the listing), each breach of the safety-device requirements (EUR 600 to EUR 6,000) and operating as a business without a SCIA (EUR 2,000 to EUR 10,000). For the same conduct the regional fine prevails (paragraph 10); the results of municipal checks are passed to the Revenue Agency, which focuses its checks on properties without a CIN (paragraphs 11 and 12).

The landlord identifies guests from an identity document and reports their personal details to the Questura di Ferrara (provincial police headquarters) within twenty-four hours of arrival through Alloggiati Web (the State Police online guest notification service), using credentials requested in advance (Article 109, paragraphs 1 and 3, of the Consolidated Public Security Act, TULPS; Ministerial Decree of 7 January 2013; for contracts of less than thirty days, Article 19-bis of Decree-Law No. 113/2018). For stays of up to twenty-four hours the Questure require notification within six hours, a time limit introduced by Decree-Law No. 53/2019 and implemented by the Ministerial Decree of 16 September 2021. Failure to notify, or late notification, is punishable, according to the Questure, by detention (arresto) of up to three months or a criminal fine (ammenda) of up to EUR 206 (Article 17 of the TULPS).

Comacchio: SUAP, tourist tax, IMU

Article 12 of Emilia-Romagna Regional Law No. 16/2004 classifies letting by a private individual as ‘appartamenti ammobiliati per uso turistico’ (furnished flats for tourist use): up to three units, contracts of up to six consecutive months, no additional services, notification to the Municipality (according to the regional information sheet, with a written contract, the entire dwelling let to a single household and filing through Accesso Unitario, the Emilia-Romagna online filing platform), as a rule by 31 March in summer resort areas (paragraph 2; fine of EUR 50 to EUR 100, Article 36, paragraph 10), submission of statistical data to the Region and compliance with public security rules (paragraph 3). The regional SUAP information sheet states ‘massimo due unità’ (two units at most) in the definition and ‘massimo 3 appartamenti’ (3 flats at most) among the requirements (three according to the municipal FAQ), and regards booking channels as an indicium of business activity. In our view, Article 4, paragraph 1, of Decree-Law No. 50/2017, which allows the use of portals, prevails, but it is advisable to keep listings to the essentials, without further services.

From 2026, however, with three flats in short-term letting, national law presumes a business and requires a SCIA to be filed with the SUAP (Article 13-ter, paragraph 8). In our view the third flat should be set up as ‘case e appartamenti per vacanze’ (holiday homes and flats), even though Article 11, paragraph 2, of the regional law treats as a business only a person who lets more than three.

The imposta di soggiorno has applied in Comacchio since 1 December 2017 (regulation approved by Municipal Council Resolution No. 77 of 27 July 2017); the new regulation published for 2026 does not state the details of its approval. The 2026 rates, confirmed by Municipal Executive Resolution No. 250 of 24 October 2025, apply per person per night up to fourteen consecutive nights: EUR 0.50 in furnished flats for tourist use (Annex A), with children up to the age of twelve exempt. Whoever collects the rent, landlord or portal, is liable for payment of the tax, with a right of recourse against the guest, and files the electronic return by 30 June of the following year (Article 4, paragraph 5-ter, of Decree-Law No. 50/2017; from 2027 Article 208, paragraph 4, of Legislative Decree No. 117/2026).

The landlord registers on SOGGIORNIAMO on starting the activity, issues a receipt, and each quarter reports and pays over the tax collected by the middle of the following month (on 15 April, July, October and January according to the municipal web page, on the 16th according to the new regulation); the landlord also renders the conto della gestione (the collecting agent’s annual statement of account) on Form 21 by 30 January. For bookings collected by Airbnb, which has operated under an agreement with the Municipality since 1 October 2023 (Management Decision No. 1042/2023), the portal pays the tax; for other channels, bank transfers included, the landlord pays, checking the arrangements of each intermediary with the Ufficio Tributi (municipal tax office).

The 2026 IMU rate schedule (Municipal Council Resolution No. 84 of 22 December 2025, ID 13703 on the fiscal federalism portal) sets 1.14% for other buildings, the maximum rate including the increase under Article 1, paragraph 755, of Law No. 160/2019, with no reductions for tourist lets. With a cadastral income (rendita) of EUR 500, the taxable base is 500 × 1.05 × 160 = EUR 84,000 and the tax EUR 957.60, payable in two instalments of EUR 478.80.

In practice

• Before the first listing: written contracts, notification to the SUAP through Accesso Unitario, application for the CIN with the cadastral data and a statement on the safety devices, code displayed and shown in listings.
• On each arrival: Alloggiati Web within twenty-four hours (six if the stay is no longer than that) and a receipt for the tourist tax, unless the portal collects it.
• Each quarter, even with no guest nights: guest nights reported on SOGGIORNIAMO and payment through PagoPA by 15 April, 15 July, 15 October and 15 January; by 30 January, Form 21.
• By 30 June of the following year: electronic tourist tax return to the Revenue Agency.
• Income tax return: Schedule RB with the option for the cedolare, the choice of the unit taxed at 21% and the crediting of the certified withholdings.
• IMU: instalments on 16 June and 16 December.
• Retention for five years, including for files handled by the Codigoro office: contracts, Certificazioni Uniche, tourist tax and Alloggiati Web receipts, the CIN certificate, and the documents for extinguishers and detectors.

Frequently asked questions

I let two flats in Lido di Spina and a house in Codigoro under an annual contract: do I lose the cedolare?

No. The threshold concerns the units allocated to short-term letting; the house let under an ordinary registered contract is left out of the count and keeps the cedolare at 21%, provided it is unconnected with any business activity.

The portal withholds 21%: do I still have to pay anything?

On the unit chosen for the 21% rate the withholding covers the cedolare. On the second unit the withholding remains at 21% and the five percentage points needed to reach 26% are paid with the balance due under the tax return.

Who pays the tourist tax if I collect the rent myself by bank transfer?

The landlord, who collects it from the guest against a receipt and reports and pays it over to the Municipality of Comacchio each quarter, by the middle of the following month, through the SOGGIORNIAMO application. The landlord also renders the annual statement of account by 30 January and files the electronic return by 30 June. If the booking is collected by Airbnb, a portal that has had an agreement with the Municipality since 1 October 2023, the tax is paid by the portal; for other portals the arrangements must be checked with the Ufficio Tributi, because by law whoever collects the rent is liable.

Sources

Decree-Law No. 50 of 24 April 2017, Article 4, converted into law by Law No. 96 of 21 June 2017 (Normattiva, text in force on 2 November 2026)

Law No. 178 of 30 December 2020, Article 1, paragraph 595; Law No. 199 of 30 December 2025, Article 1, paragraph 17 (Normattiva)

Legislative Decree No. 23 of 14 March 2011, Articles 3 and 4; Presidential Decree No. 917 of 22 December 1986, Article 37, paragraph 4-bis; Legislative Decree No. 117 of 19 June 2026, Articles 39, 203, 207 and 208 (applicable from 1 January 2027)

Decree-Law No. 145 of 18 October 2023, Article 13-ter, converted into law by Law No. 191 of 15 December 2023 (Normattiva)

Royal Decree No. 773 of 18 June 1931, Article 109; Decree-Law No. 113 of 4 October 2018, Article 19-bis (Normattiva); Decree of the Ministry of the Interior of 7 January 2013, as amended by the Decree of 16 September 2021 (Official Gazette No. 246 of 14 October 2021); Decree-Law No. 53 of 14 June 2019, Article 5; Polizia di Stato (State Police), Alloggiati Web service; Presidential Decree No. 131 of 26 April 1986, Tariff, Part Two, Article 2-bis; Legislative Decree No. 123 of 1 August 2025, Annex 1, Tariff, Part Two, Article 3 (applicable from 1 January 2027)

Law No. 160 of 27 December 2019, Article 1, paragraph 755 (Normattiva)

Italian Revenue Agency: Circular No. 24/E of 12 October 2017; Circular No. 10/E of 10 May 2024; guide ‘Locazioni brevi: la disciplina fiscale e le regole per gli intermediari’, April 2026

Emilia-Romagna Region: Regional Law No. 16 of 28 July 2004, Articles 11, 12, 35-bis and 36 (Demetra); SUAP information sheet ‘Appartamenti ammobiliati uso turistico’ (which cites the circular with an incorrect number and year); circular ref. No. 951915 of 5 September 2024 on the CIN

Municipality of Comacchio: Municipal Executive Resolution No. 250 of 24 October 2025 (2026 tourist tax rates); regulation approved by Municipal Council Resolution No. 77 of 27 July 2017; online services desk, page ‘Versare l’imposta di soggiorno (IDS)’; Annex A ‘Tariffe IDS 2026’; tourist tax regulations (new text published without the details of its approval); SUAP FAQ ‘Appartamenti ammobiliati ad uso turistico’; 2026 IMU rate schedule ID 13703 (Municipal Council Resolution No. 84 of 22 December 2025) on the fiscal federalism portal