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2026 company tax returns: how to correct them and what it costs

VAT and Redditi 2026 deadlines passed: amended returns, cost of voluntary disclosure with an example, credits to recover, new items to recheck in companies.

The ordinary deadlines for the 2026 tax returns have passed: the VAT return was due on 30 April, the income tax return (modello Redditi) and the IRAP (regional tax on productive activities) return on 2 November (31 October fell on a Saturday). Anyone who finds an error corrects it with an amended return (dichiarazione integrativa) and, if too little tax was paid, pays through voluntary disclosure (ravvedimento operoso) a penalty far lower than the one the Revenue Agency (Agenzia delle entrate) would impose. For Redditi 2026 the largest reduction applies for ninety days from the deadline: to be prudent, by Friday 29 January 2027; counting from the deadline postponed to 2 November, it runs to Monday 1 February.

The framework

Amended return. Redditi, IRAP and VAT returns can be amended, in the taxpayer’s favour or against it, within the time limit for assessment, i.e. 31 December of the fifth year following that of filing: for returns filed in 2026, 31 December 2031 (Art. 2, para. 8, and Art. 8, para. 6-bis, Presidential Decree 322/1998; Art. 43 Presidential Decree 600/1973; Art. 57 Presidential Decree 633/1972).

Credits arising from the amended return. If the amended return in the taxpayer’s favour is filed by the deadline for the return for the following year, the credit can be used immediately (for VAT, also in periodic settlements); if it is filed later, the credit can offset only debts arising from the period following that of filing and must be reported in the return for that year (Art. 2, para. 8-bis, and Art. 8, paras. 6-ter and 6-quater, Presidential Decree 322/1998). For income taxes, immediate offsetting nonetheless remains permitted where accounting errors relating to the period of accrual (errori di competenza) are corrected.

Late or omitted return. A return filed within ninety days of the deadline is valid; beyond that, it is deemed omitted (Art. 2, para. 7, Presidential Decree 322/1998). For the 2026 VAT return the deadline expired at the end of July, and on an omitted return the Revenue Agency may assess the tax on the basis of electronic invoices, daily takings data (corrispettivi) and periodic VAT settlement communications (LIPE), deducting only the payments made and without the credit for the previous year; a return lacking the sections needed for the settlement is also treated as omitted (Art. 54-bis.1 Presidential Decree 633/1972).

Penalties and voluntary disclosure. For violations from 1 September 2024, an inaccurate return is penalised at 70% of the additional tax, with a minimum of EUR 150 (Art. 1, para. 2, and Art. 5, para. 4, Legislative Decree 471/1997). Within ninety days of the filing deadline, according to the Revenue Agency, the amended return does not constitute inaccuracy: the penalty under Art. 8, para. 1, Legislative Decree 471/1997 reduced to one ninth (EUR 27.78) is paid, together with the penalty for non-payment, 25% of the additional tax (Art. 13, para. 1, Legislative Decree 471/1997), reduced according to the date of payment (Circular 42/E of 12/10/2016, para. 2.2.1). Beyond ninety days, the violation is inaccuracy, which absorbs the penalty for non-payment (para. 3.1.1). If the inaccuracy emerges from an amended return filed before the taxpayer has had formal notice of tax access visits, inspections, audits or the start of any administrative assessment activity, the penalty is 50% of the additional tax (Art. 1, para. 2-bis, and Art. 5, para. 4.1, Legislative Decree 471/1997); with voluntary disclosure it is reduced to one eighth by the deadline for the return for the year in which the violation was committed (for Redditi 2026, the Redditi 2027 deadline; for VAT 2026, 30 April 2027) and to one seventh thereafter (Art. 13, para. 1, letters b and b-bis, Legislative Decree 472/1997). As regards combining the reduced rate with the voluntary disclosure reductions, it is prudent to also run the calculation on the 70% basis. Tax, reduced penalties and statutory interest are paid together (Art. 13, para. 2, Legislative Decree 472/1997).

What changes in concrete terms

An srl (limited liability company) discovers that it deducted an invoice of EUR 5,000 twice in its Redditi SC 2026 return. Considering IRES (corporate income tax) only, the additional tax at 24% is EUR 1,200 and the full penalty for inaccuracy EUR 840. With an amended return and payment by 29 January 2027, the company pays EUR 27.78 (one ninth of EUR 250) plus the penalty for the unpaid balance, 25% of EUR 1,200 reduced to one eighth, i.e. EUR 37.50: EUR 65.28 in total. Beyond ninety days, on the 50% basis (EUR 600): EUR 75 by the Redditi 2027 deadline, EUR 85.71 thereafter; on the prudential 70% basis, EUR 105 and EUR 120. The EUR 1,200 of tax and interest from the balance payment deadline must always be added; if the cost is relevant for IRAP, the calculation is repeated on the IRAP return. As a prudential measure, companies that calculated the 2026 advance payments using the historical method pay the second advance, by Monday 30 November 2026, on the corrected basis and regularise the shortfall on the first advance through voluntary disclosure. If the Revenue Agency finds the error, the starting point is EUR 840.

For VAT, if the previous year’s credit was carried forward in the 2026 return EUR 3,000 too low, an amended return filed by 30 April 2027 makes the amount immediately usable; after that date, only against debts of subsequent years or by refund, where the conditions are met.

When reviewing the 2026 returns, it is worth focusing on the new items: transactions subject to the option for VAT to be paid by the customer in the logistics sector, to be reported in the lines provided by the instructions to the 2026 VAT return (Art. 1, paras. 59-63, Law 207/2024); the requirements for the four-point reduction in IRES for 2025, including investments made by the Redditi 2026 deadline (Art. 1, paras. 436-444, Law 207/2024); and the spreading of capital gains on individual assets realised in 2025, the last spreading allowed, which must be shown in the return (Art. 86, para. 4, of the Consolidated Income Tax Act, TUIR).

In practice

• Directors and their accountants review the 2026 returns now: an error corrected and paid by 29 January 2027 costs less.
• The amended return is filed electronically on the 2026 form for the tax being corrected, with payment by F24 of tax, reduced penalties and interest.
• In partnerships and in tax-transparent srls, amended returns are also required for the shareholders to whom the income is attributed.
• The calculation schedule, filing receipts, paid F24 forms and documents relating to the error are kept at least until 31 December 2031.

Mistakes to avoid

• Filing the amended return and postponing payment: without payment there is no voluntary disclosure.
• Waiting for the Revenue Agency to find the error: once the results of automated or formal checks, or a settlement or assessment notice, have been served, voluntary disclosure is no longer possible (Art. 13, para. 1-ter, Legislative Decree 472/1997).
• Correcting a 2024 error in the 2025 financial statements in the belief that this also settles the tax position: the correction has tax effect only for companies subject to a mandatory statutory audit and for non-material errors (Art. 83, para. 1-ter, TUIR); otherwise an amended return for the year of accrual is required.
• Distributing by 2026 (for a calendar financial year) the 2024 profit set aside for the reduced IRES: the relief is forfeited.
• Sending a VAT return without the sections needed for the settlement: for the Revenue Agency’s automated settlement it counts as omitted, so the tax is recalculated from invoices, daily takings and LIPE, without the previous year’s credit (Art. 54-bis.1 Presidential Decree 633/1972).

References

Presidential Decree no. 322 of 22/7/1998, Art. 2, paras. 2, 7, 8 and 8-bis, and Art. 8, paras. 6-bis, 6-ter and 6-quater

Decree-Law no. 70 of 13/5/2011, Art. 7, para. 1, letter h)

Presidential Decree no. 600 of 29/9/1973, Art. 43

Presidential Decree no. 633 of 26/10/1972, Arts. 54-bis.1 and 57

Legislative Decree no. 471 of 18/12/1997, Art. 1, paras. 1, 2 and 2-bis, Art. 5, paras. 4 and 4.1 (Legislative Decree no. 87 of 14/6/2024), Art. 8, para. 1, and Art. 13, para. 1

Legislative Decree no. 472 of 18/12/1997, Art. 13

Law no. 207 of 30/12/2024, Art. 1, paras. 59-63 and 436-444

Law no. 212 of 27/7/2000, Art. 6-bis

TUIR, Art. 83, para. 1-ter (Legislative Decree no. 192 of 18/12/2025) and Art. 86, para. 4

Agenzia delle entrate, Circular no. 42/E of 12/10/2016, paras. 2.2.1 and 3.1.1. From 1 January 2027 the TUIR provisions move into the consolidated income tax code (Legislative Decree no. 117 of 19/6/2026), those on penalties and voluntary disclosure into the consolidated code of tax penalties (Legislative Decree no. 173 of 5/11/2024), those on assessment and the related time limits (Art. 43 Presidential Decree 600/1973, Arts. 54-bis.1 and 57 Presidential Decree 633/1972) into the consolidated code on compliance and assessment (Legislative Decree no. 141 of 5/8/2026) and the other VAT provisions into the consolidated VAT code (Legislative Decree no. 10/2026), with different article numbering

Presidential Decree 322/1998 remains in force