The 2025 Budget Law (L. 207/2024) introduced, applicable only to the tax period following the one in progress on 31.12.2024, a significant tax incentive: the application of a reduced IRES rate of 20% (as opposed to 24%) for corporations that meet specific requirements.
With Ruling No. 81/2025, the Italian Tax Authorities have addressed a case of international taxation regarding the payment of a Long-Term Cash Bonus to an employee who had returned to Italy. The Authorities clarified that taxation must occur in the country where the work activity was effectively carried out during the vesting period, regardless of the beneficiary’s tax residence at the time of payment.
2025 Budget Law (Law no. 207/2024) Paragraph 30 lays out the official framework for the revaluation of tax expenditure regarding equity holding (both listed and unlisted) and land (agricultural and developable), consolidating a provision that has been subject to numerous extensions in the past.
Law 166/2024 was published in the Official Journal under number 267 of 14 November 2024, converting Legislative Decree 131/2024 (the so-called EU Infringement Rescue Decree), and contains provisions for the closure of a series of infringement procedures with the European Union, including one concerning the VAT regime for the secondment of personnel.
The Italian Tax Revenue Agency, with the publication of ministerial memorandum no. 20/E of 4 November, reveals the effects of the changes introduced by Legislative Decree 209 of 2023 (Implementation of tax reform in international taxation) regarding the tax residence of individuals, companies and entities that have been operational starting from 2024.
The Italian Tax Revenue Agency, in response to question no. 200 of 11 October 2024, considered a series of extraordinary transactions consisting of two induced neutrality transfers (pursuant to art. 177 co. 2 and 2-bis of the TUIR, Italy’s Consolidated Law on Income Tax) and a merger to be evasive.
On 30 September 2024, pursuant to article 38-bis, paragraph 2 of Presidential Decree 600/73, provision no. 372380 of the Tax Revenue Agency was published, clarifying the procedures for signing tax audit reports issued at the conclusion of administrative tax control activities by the members of the Tax Revenue Agency.
Upon the introduction of Legislative Decree 108/2024 – Official Gazette no. 182 on 5 August 2024, amendments to Legislative Decree 128/2015 were passed which integrated the provisions of the cooperative compliance regime (a recent topic of discussion from 15 July 2024).
Legislative Decree no. 13 from 12 February 2024, with the aim of reinforcing cooperative compliance institutions, has established the Biennial Preventive Agreement (BPA) through which, upon the reaching of an agreement between the Italian Tax Agency and an individual tax payer, the latter shall be able to determine, for a two-year period, the income which derives from the exercise of its business or from that of trade and business-related to income tax and IRAP (regional tax on productive activities) purposes. The new institution does not, however, impact current VAT regulations.
Legislative decree no. 128/2015 signed into legislation the Cooperative Compliance Regime with the aim of promoting stronger forms of communication and cooperation between the Italian Tax Authorities and taxpayers whose framework includes systems for detection, measurement, management and control of tax risks and exposure.
