News · Business taxation · – October 2026
Art. 21, paragraph 1, of Law 111/2023, as amended by art. 1, paragraph 1, letter e), of Law 120/2025, empowers the Government to reorganise the tax system into consolidated tax Acts (testi unici) by 31 December 2026. Eight consolidated Acts have been published: administrative and criminal tax penalties (Legislative Decree (d.lgs.) 173/2024), minor state taxes (d.lgs. 174/2024), tax justice (d.lgs. 175/2024), payments and collection (d.lgs. 33/2025), registration tax and other indirect taxes (d.lgs. 123/2025), VAT (d.lgs. 10 of 19 January 2026), income taxes (d.lgs. 117 of 19 June 2026) and compliance and assessment (d.lgs. 141 of 5 August 2026). All of them apply with effect from 1 January 2027: for the first five, the date of 1 January 2026 was replaced by art. 4, paragraphs 1 to 5, of Decree-Law (d.l.) 200 of 31 December 2025, converted into law by Law 26/2026; for the other three it is set by arts. 171 of d.lgs. 10/2026, 377 of d.lgs. 117/2026 and 368 of d.lgs. 141/2026. Each consolidated Act repeals the provisions it incorporates: art. 376, paragraph 1, letter e), of d.lgs. 117/2026 repeals arts. 1 to 191 of Presidential Decree (d.P.R.) 917/1986; art. 170, paragraph 1, letter a), of d.lgs. 10/2026 most of d.P.R. 633/1972 and Tables A, B and C; art. 367, paragraph 1, letters h) and bb), of d.lgs. 141/2026 a large part of d.P.R. 600/1973 and arts. 1 to 17 of d.lgs. 218/1997, whose assessment by agreement (accertamento con adesione) moves to arts. 345 to 363 of the consolidated Act. Under a common clause (art. 101, paragraph 3, of d.lgs. 173/2024; art. 170, paragraph 3, of d.lgs. 10/2026; art. 376, paragraph 2, of d.lgs. 117/2026; art. 367, paragraph 3, of d.lgs. 141/2026), references in laws, regulations, decrees or other rules or measures to expressly repealed provisions are read as references to the corresponding provisions of the consolidated Act, as indicated in each article, unless otherwise provided and except where repeal results from incompatibility; each article states, below its heading, the provisions from which it derives.
The reorganisation does not halt 2026 legislation, which amends in parallel the provision in force and the article of the consolidated Act that will replace it: art. 14 of d.lgs. 148 of 7 August 2026, a corrective decree of the reform, amends art. 34 of d.lgs. 346/1990 in paragraph 1 and art. 309 of the consolidated Act on compliance and assessment in paragraph 2. D.lgs. 141/2026, which in arts. 2 to 8 lays down coordinating and corrective provisions for the other seven consolidated Acts, in turn completes the transposition: art. 8, paragraph 1, letter f), inserts paragraph 10-bis into art. 27 of the consolidated Act on penalties, taking over the penalty of 25 to 50 per cent laid down in art. 8, paragraph 2, of d.l. 16/2012 for expenses relating to goods or services not actually exchanged or supplied, while the assessment rule moves to art. 255 of the consolidated Act on compliance and assessment. On 13 October 2026 the Council of Ministers approved on preliminary examination, under art. 1, paragraph 6, of Law 111/2023, a draft coordinating and corrective legislative decree covering all eight consolidated Acts, which updates legislative references, corrects typographical errors and completes the transposition of provisions in force, and which corrects the placement of some amendments and some cross-references in d.lgs. 141/2026 and 148/2026. It remains a draft: it must obtain the opinions of the parliamentary committees under art. 1, paragraphs 2 and 3, of the enabling law. Its content may therefore change and only the decree published in the Official Gazette (Gazzetta Ufficiale) will count. In our view, art. 367, paragraph 1, of d.lgs. 141/2026, which links the repeals to the “date of entry into force of this consolidated Act”, should be read together with art. 368, with effect from 1 January 2027, as the other consolidated Acts expressly provide; a clarification in the corrective decree would be advisable.
Summary note by the CommercialistiAvvocati network, based on specialised legal and practice sources. The text does not reproduce original contributions and does not constitute professional advice.