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Professionals and farmers: what changes with the IRPEF reform

Itemised expense reimbursements and traceability, sale and contribution of a practice, carbon credits and crops in buildings: rules in force and examples.

Since 2024, a professional’s income has included everything received in connection with the activity, no longer just fees; since 2025, expense reimbursements charged on an itemised basis have been excluded from income, but for meals, accommodation, taxis and chauffeur-driven hire vehicles (noleggio con conducente, NCC) in Italy only if paid by traceable means. For land, crops grown in sheds and other buildings and carbon credits fall within agricultural income (reddito agrario), within limits beyond which business income (reddito d’impresa) applies.

The framework

Legislative Decree no. 192 of 13 December 2024 replaced Art. 54 of the Consolidated Income Tax Act (Testo unico delle imposte sui redditi, TUIR) with Arts. 54 to 54-octies, applicable from the 2024 tax period (Art. 6, para. 1); the rules on expense reimbursements apply from 2025. Decree-Law no. 84 of 17 June 2025, converted by Law no. 108 of 30 July 2025, amended the rules on traceability and shareholdings.

• All-inclusive principle (Art. 54, para. 1): all sums received on any basis in connection with the activity form part of income. A fee paid in one year and credited in the following year is attributed to the year in which the client was required to withhold tax, if the client is a withholding agent (sostituto d’imposta); if a private individual pays, the year of crediting applies.
• Itemised reimbursements (Art. 54, para. 2, letter b, and Art. 54-ter): they are not income and the expense is not deductible. For meals, accommodation and taxi or NCC journeys incurred in Italy and paid without traceable instruments, the reimbursement becomes income again (Art. 54, para. 2-bis, for expenses incurred from 1 January 2025; Revenue Agency Circular 15/E of 22/12/2025). Trains, planes and buses remain outside the requirement, which, for transport, covers only taxis and NCC.
• Unreimbursed expenses (Art. 54-ter, paras. 2-5): they are deductible after insolvency proceedings, an unsuccessful enforcement or the expiry of the limitation period; for amounts up to EUR 2,500, fee included, once one year has elapsed from the invoice. Here too, meals, accommodation, taxis and NCC incurred in Italy must be paid by traceable means (para. 5-bis).
• Shareholdings (Art. 54, para. 3-ter): capital gains on interests in professional associations and professional services companies (società tra professionisti, STP) are miscellaneous income (redditi diversi) from 2024. Interest is investment income (redditi di capitale) (para. 3-bis).
• Reorganisations (Art. 177-bis): contributions to an STP, contributions to associations, transformations, mergers, demergers and transfers by succession or gift of an organised practice are tax-neutral, with continuity of values; under para. 4-bis these transactions, and the subsequent sale of the interests received, are not relevant for abuse-of-law purposes (Art. 10-bis Law 212/2000).

For land, Art. 1 of the same decree applies from 2024 income. Art. 32, para. 2, letter b-bis, brings into agricultural income the production of plants in buildings in cadastral categories C/1, C/2, C/3, C/6, C/7, D/1, D/7, D/8, D/9 and D/10, within twice the reference agricultural area. Pending the implementing decree, income is calculated using the highest land valuation rate (tariffa d’estimo) in the province, increased by 400 per cent (Arts. 28, para. 4-ter, and 34, para. 4-bis); the landowner’s income (reddito dominicale) so obtained may not in any case be lower than the cadastral income (rendita catastale) of the property (Art. 28, para. 4-quater). Letter b-ter does the same for assets, including intangible assets, related to environmental protection, such as certified carbon credits, up to the consideration from sales of agricultural goods; on the excess, business income equals 25 per cent of the consideration (profitability coefficient, Art. 56-bis, para. 3-ter), and ordinary taxes are then paid on that income.

From 1 January 2027 these rules move into the consolidated income tax code (testo unico delle imposte sui redditi, Legislative Decree no. 117 of 19 June 2026), with different article numbering.

What changes in concrete terms

The professional’s reimbursements. A consultant with income above EUR 50,000 invoices a fee of EUR 2,000 and, on separate lines, EUR 420 for hotel and train, documented and paid by card. Only the EUR 2,000 enters income and the 20 per cent withholding tax, EUR 400, applies to the fee alone, because from 2025 the itemised reimbursement is no longer income (Art. 54, para. 2, letter b, TUIR; Art. 6, para. 2, Legislative Decree 192/2024). Had the hotel, EUR 300 of the EUR 420, been paid in cash, that reimbursement would become income with no deduction for the expense: at the 43 per cent rate of IRPEF (personal income tax), EUR 129 of additional tax, excluding regional and municipal surcharges (addizionali). Those under the flat-rate regime (regime forfetario) approaching the EUR 85,000 and EUR 100,000 thresholds (Law 190/2014, Art. 1, paras. 54 and 71) would do well to check how to treat reimbursements before invoicing them.

Sale and contribution of the practice. The price paid for the client base is professional income, or is subject to separate taxation if collected, even in several instalments, within the same year (Art. 17, para. 1, letter g-ter). The sale of an interest in an association or an STP instead gives rise to miscellaneous income, with a 26 per cent substitute tax. The contribution of the practice to an STP is not taxed: the company takes over the professional’s position (Art. 177-bis, para. 1) and what the professional has already taxed is not taxed again (para. 4); fees not yet collected at the date of the contribution must be listed in the deed and tracked until collection, so that they neither escape income nor are taxed twice.

Carbon credits. A sole-proprietor farm sells produce for EUR 80,000, invoices EUR 15,000 of services performed with its own machinery and sells carbon credits for EUR 95,000. The limit is EUR 80,000, because the rule refers only to sales of goods and services do not count; the excess of EUR 15,000 (95,000 minus 80,000) gives business income of EUR 3,750 (15,000 x 25%), which is added to other income and subject to IRPEF.

In practice

• Professionals: fee and reimbursements on separate invoice lines, receipts kept; from 2025, hotels, restaurants, taxis and NCC in Italy paid by card, bank transfer or other traceable means.
• Clients: withholding on the fee alone if the reimbursement is itemised and documented; in full on flat-rate reimbursements, which are fees.
• Practices undergoing reorganisation: deed of contribution or transformation, reconciliation schedule in the income tax return, list of receivables not collected at the date of the transaction.
• Farms: at year-end, a schedule separating sales of goods from services and comparing sales of goods with carbon credits sold, kept together with the certificates; for crops grown in buildings, a cadastral extract (visura) of the property showing its cadastral income, and the area of the land parcel, to compare the two measures.

Mistakes to avoid

• Deducting an expense already reimbursed on an itemised basis.
• Paying in cash for hotels, restaurants or taxis to be recharged.
• Calling a flat-rate sum an “expense reimbursement”: it is a fee.
• Invoicing reimbursements without VAT: they remain part of the taxable amount, except for advances made in the name and on behalf of the client (Art. 15, no. 3, Presidential Decree 633/1972).
• Including services within the carbon credit limit.

References

Presidential Decree no. 917 of 22 December 1986, Arts. 17, 28, 32, 34, 54, paras. 1, 2, 2-bis, 3-bis and 3-ter, 54-ter, paras. 2-5 and 5-bis, 54-septies, 56-bis, 67 and 177-bis, paras. 1, 4 and 4-bis

Law no. 212 of 27 July 2000, Art. 10-bis

Legislative Decree no. 192 of 13 December 2024, Arts. 1, 5 and 6

Decree-Law no. 84 of 17 June 2025, converted by Law no. 108 of 30 July 2025, Art. 1

Presidential Decree no. 600 of 29 September 1973, Art. 25

Presidential Decree no. 633 of 26 October 1972, Art. 15

Legislative Decree no. 461 of 21 November 1997, Art. 5

Law no. 190 of 23 December 2014, Art. 1, paras. 54-89

Agenzia delle entrate Circular 15/E of 22 December 2025

Legislative Decree no. 117 of 19 June 2026