Tax news · – September 2026
The concordato preventivo biennale (two-year advance tax arrangement) rests on d.lgs. 12 febbraio 2024, n. 13: ISA taxpayers qualify (art. 10, comma 1) with no 2025-2026 arrangement in force, while Capo III (regime forfetario, flat-rate regime) was repealed from 1 January 2025 (art. 7, d.lgs. 81/2025). The ordinary deadline, 30 September (art. 9, comma 3), was deferred for 2026-2027 to 31 October 2026 by art. 7-bis, comma 3, del d.l. 27 marzo 2026, n. 38, converted by legge 88/2026. Falling on a Saturday, it moves to the next working day under art. 7, comma 2, lettera l), d.l. 70/2011: Monday 2 November 2026. From 1 January 2027 d.lgs. 5 agosto 2026, n. 141 repeals artt. 9, 10, 11 and 18, the arrangement continuing in artt. 89-111 of the testo unico.
Art. 11 excludes, among others, those who omitted one of the three preceding returns, those entering the regime forfetario in the first year, those with exempt or excluded income above 40 per cent of business or professional income, companies involved in a merger, demerger or contribution, and the companies and associations under art. 5 del TUIR whose number of partners increases; an election despite a ground for exclusion has no effect (comma 1-bis). Once accepted, actual income is disregarded for income taxes, IRAP (Italian regional business tax) and contributions (art. 19), while IVA (Italian VAT) is unaffected (art. 18). Forfeiture under art. 22 covers not only variances above 30 per cent but also breaches that are not minor and non-payment of the sums assessed under art. 12, comma 2.
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.