Law No. 207 of 30 December 2024 on the ‘State Budget for the Financial Year 2025 and the Multiannual Budget for the Three-Year Period 2025-2027’, in force since 1 January 2025, introduces several important innovations. We analyse the main interventions that affect businesses, families and workers.
TAX INNOVATIONS FOR COMPANIES
LIMIT FOR THE APPLICATION OF THE FLAT RATE SYSTEM
Art. 1, par. 12
The limit of employee (and assimilated) income above which one cannot enter the flat-rate scheme is raised to € 35,000.00. The termination of employment is not relevant for the verification of this threshold.
WEB TAX
Art. 1, paragraphs 21-22
The minimum limit of € 5.5 million of revenues in Italy for the application of the tax is eliminated for
– advertising on websites and social networks
– management of digital platforms;
– transmission of user data.
Thus, all companies that realise, within the territory of the State, any amount of revenue from these digital activities and that realise, anywhere in the previous calendar year, total revenues of not less than € 750 million, individually or at group level, are subject to this. In fact, the latter requirement is confirmed with respect to the previous legislation.
Payment in 2 instalments:
– 30% by 30 November;
– Balance by 16 May of the following year.
RESTATEMENT OF COST OF PARTICIPATIONS AND LAND
Art. 1, par. 30
The possibility of revaluing the purchase cost of participations, whether or not traded, and of building land and land for agricultural use, held as of 1 January, is confirmed at regime, provided that, by 30 November
– substitute tax is paid, which rises from 16% to 18%, with the possibility of instalment in 3 years, with the same amount, and with interest at 3% on the 2nd and 3rd instalments.
– report certified by Chartered Accountants and Accounting Experts, Legal Auditors, and enrolled in the Chamber of Commerce rolls.
FACILITATED ASSIGNMENT OF ASSETS TO SHAREHOLDERS
Art. 1, par. 31-36
It is re-proposed for:
– Snc, Sas, Srl, Spa, Sapa,
– Companies with the exclusive or main purpose of managing immovable or movable property registered with the Pra, not instrumental, and which transform into simple companies by 30 September 2025
the possibility to pay a substitute tax equal to 8% (10.5% if a company is not operative in at least 2 of the 3 previous tax periods) on the difference between the normal value and the fiscally recognised cost of real estate or movable property registered with the Pra, not instrumental, assigned or sold to shareholders by 30 September 2025.
REMOVAL OF ASSETS OF SOLE PROPRIETORSHIPS
Art. 1, par. 37
Individual entrepreneurs may oust from the company’s assets, capital real estate not producing land income, owned on 31/10/24 provided that
– the exclusion takes place between 01/01/2025 and 31/05/2025;
– a substitute tax for IRPEF and IRAP is paid equal to 8% of the difference between the normal value of the assets and the value recognised for tax purposes.
CAR FRINGE BENEFITS
Art. 1, par. 48
Decrease taxation on certain vehicles granted for mixed use as of 1 January 2025, specifically on electric cars to 10% and plug-in hybrids to 20%, by the amount corresponding to a conventional mileage of 15,000 km and cost per kilometre based on the tables drawn up by ACI and published by the Agenzia delle Entrate every year and effective as of 1 January.
REVERSE CHARGE EXTENSION
Art. 1, par. 57-63
The reverse charge mechanism is extended to the provision of services rendered to transport, goods handling and logistics companies, within the scope of tender contracts, subcontracts, consortium agreements or negotiated relationships, with the prevalent use of labour and capital goods owned by the principal.
Since this provision is, however, subject to authorisation by the EU Council, it is envisaged at this stage that the supplier and the principal may choose, for a period of three years and by notifying the tax authorities, that the payment of VAT on these services is made by the principal in the name and on behalf of the supplier, who remains, however, jointly and severally liable.
INDICATION CIN
Art. 1, par. 78-79
The CIN (unique identification code) becomes compulsory for all owners of accommodation facilities and real estate units intended for short-term rental or tourism purposes. This must be displayed at the entrance of the building or facility and included in all online advertisements, as well as in tax documents and declarations required by law.
ACCESS TO E-INVOICING DATA
Art. 1, par. 80
Electronic invoice files acquired by the Sdi are stored until 31.12 of the eighth year following the year in which the reference declaration was submitted, or until new judgments are finalised, to be used also by the Customs and Monopolies Agency, and no longer only by the Guardia di Finanza and the Revenue Agency, for products subject to excise and other indirect taxes.
TRACEABILITY OF TRAVEL AND REPRESENTATION EXPENSES
Art. 1, par. 81-83
For deductibility purposes, the obligation to pay by traceable means and not in cash is imposed:
– the costs of board, lodging, travel and transport, performed by means of non-scheduled public transport services (such as taxis and car rental with driver), relating to employee travel or paid to self-employed persons;
– entertainment expenses.
CONTRIBUTION REDUCTION FOR ARTISANS AND TRADERS
Art. 1, par. 186
A new contribution reduction has been introduced for taxpayers who enrol for the first time in 2025 in one of the special autonomous INPS artisans’ and traders’ management schemes. They can benefit from a 50 per cent reduction of the social security contributions due for the first 36 months of activity.
CHANGES TO THE TRANSITION 5.0 TAX CREDIT
Art. 1, par. 427-429
The rules have been amended as follows
– Beneficiaries: the tax credit can also be granted, as an alternative to companies, to certified energy service companies (ESCo);
– investment brackets: from 3 to 2, the 15% rate was eliminated;
– rates: the measure of the tax credit recognised is 35% of the cost for the portion of investments up to € 10,000,000.00;
– access measures: for operational leasing companies, energy savings can be verified with respect to the energy consumption of the lessor’s or lessee’s facility or production process;
– cumulability of the tax credit with other facilities provided by the EU.
CHANGES TO THE TRANSITION 4.0 TAX CREDIT
Art. 1, par. 445-448
The rules are amended with reference to
– type of investment: the provision that recognised the 10% tax credit on investments in intangible assets (Appendix B Financial Act 2017) made from 01/01/25 to 31/12/25 is repealed.
The 15% tax credit remains in force for intangible assets purchased or “booked” in 2024 with down payment made by 30/06/25;
– Thresholds: a maximum limit of € 2,200 million is introduced for investments in tangible assets (Annex A Financial Act 2017) made or “booked” in 2025 with down payment made by 30/06/26.
Confirmed 20% for investments up to € 2.5 million; 10% for investments between € 2.5 million;
5% for investments between € 10 and € 20 million.
PREMIUM IRES
Art. 1, par. 436-444
An IRES reduction to 20% for business income earned in 2025 by corporations, commercial entities and non-resident companies/entities is provided for upon the fulfilment of 3 conditions
– allocation to a reserve of 80% of operating profits;
– at least 30% of this reserve (which corresponds to 24% of the profits of the 2024 financial year and in any case not less than €20,000.00) must be allocated to investments in new capital goods falling under the Transition 4.0 and 5.0 plans. These investments can also be made by means of leasing contracts and must be realised between 01.01.2025 and the deadline for submitting the tax return for the tax period following the current one on 31.12.2024;
specific parameters regarding work units and new hires of employees must be met.
TAX CREDIT FOR SME LISTINGS
Art. 1, par. 449
The tax credit for advisory fees incurred by small and medium-sized enterprises (SMEs) for listing on regulated markets or multilateral trading facilities (MTFs) is extended to 31 December 2027.
NEW SABATINI
Art. 1, par. 458-460
The support to small, micro and medium-sized enterprises for investments, in purchase and leasing, in capital goods is refinanced.
PEC OBLIGATION FOR COMPANY DIRECTORS
Art. 1, par. 860
The obligation to have a pec address is laid down for directors of companies established in corporate form.
TAX NEWS FOR INDIVIDUALS (TAXES/BONUSES/DEDUCTIONS)
IRPEF RATES
Art.1, par. 2 a)
The reduction from 4 to 3 Irpef rates, already foreseen in 2024, is confirmed.
When fully operative, they become:
- 23%, up to € 28,000.00;
- 35%, over € 28,000.00 and up to € 50,000.00;
- 43%, over € 50,000.00.
EMPLOYEE DEDUCTIONS
Art. 1, par. 4, 5, 6, 7, 8, 9, 10
The supplementary treatment referred to in Art. 1, paragraph 1 DL 3/2020 for those whose total income does not exceed € 15,000.00 is confirmed at € 1,200.00, if the IRPEF debt exceeds this amount net of deductions.
It is then recognised, for holders of employment income, excluding pensioners, who have a total income of € 20000.00, an exempt amount by applying the following percentages:
- 7.1% if the employee’s income does not exceed EUR 8,500,
- 5.3% if the employment income exceeds €8,500 but not €15,000
- 4.8% if employment income exceeds €15,000
A deduction from the gross Irpef debt, related to the period of employment, is recognised for employees, excluding pensioners, who have a total income of more than €20,000.00, in the amount of
– € 1,000.00 for income exceeding € 20,000.00 but not exceeding € 32,000.00
– € 1,000.00 multiplied by the difference between € 40,000.00 and total income divided by € 8,000.00 for income exceeding € 32,000.00 but not exceeding € 40,000.00
For persons with a total income exceeding € 75,000.00, there is a deduction from the gross tax by an amount calculated on the multiplication of specific basic amounts and pre-established coefficients based on the number of fiscally dependent children.
DEDUCTIONS FOR DEPENDENT FAMILY MEMBERS
Art. 1, par. 11
Certain amounts are recognised for the following dependents
- € 950 for each child, including recognised children born out of wedlock, adopted, affiliated or fostered children, children of a deceased spouse cohabiting with a surviving spouse who are aged 21 or over but under 30, or aged 30 or over with an established disability;
- € 750.00 for each cohabiting ascendant relative, prorated
. DEDUCTIONS FOR SCHOOL EXPENSES
Art. 1, par. 13
The maximum deductible expenditure is increased to € 1,000.00 per pupil or student attending pre-school, first cycle of education and secondary school.
BUILDING BONUSES
Art. 1 par. 54 – 56
The deduction is reduced from 50% to 36% for building heritage recovery and energy requalification works carried out from 01/01/2025 to 31/12/25, with a further reduction in subsequent years, except for first homes for which it is confirmed at 50% in 2025.
The limit of € 96,000.00 per real estate unit remains.
SISMA BONUS
Art. 1 par. 54 – 56
The deduction is reduced from 50% to 36% for expenses incurred in 2025, with a further decrease in subsequent years, with the exception of first homes for which it is confirmed at 50% in 2025.
FURNITURE BONUS
Art. 1 par. 54 – 56
The 50% Irpef deduction, with a maximum amount of € 5,000.00, on the purchase of furniture/large household appliances, intended for a property undergoing renovation, is extended to 2025.
BONUS HOME APPLIANCES
Art. 1 par. 54
A contribution of 30% of the purchase cost of a household appliance of energy class no lower than B, not exceeding € 100.00, is recognised.
ECOBONUS
Art. 1 par. 54 – 56
The deduction is reduced to 36% for expenses incurred in 2025, with a further reduction in subsequent years, except for first homes for which it is confirmed at 50% in 2025.
NEW BIRTH BONUS
Art. 1, par. 206-208
An exempt one-off amount of € 1,000.00 is confirmed upon fulfilment of certain conditions.
DE-TAXATION OF PERFORMANCE BONUSES
Art. 1, par. 385
The substitute tax rate on productivity bonuses, pursuant to Art. 1, paragraph 182 of Law no. 208/2015, paid in the years 2025, 2026 and 2027, is reduced from 10 to 5 per cent.
INCREASE IN THE FRINGE BENEFIT LIMIT
Art. 1, par. 390-391
The exemption limit is raised to € 1,000.00 for all employees and to € 2,000 for employees with tax dependent children.
TIP DETAXATION
Art. 1, par. 520
Tips may be taxed at a flat rate of 5%, up to 30% of the income received.
LEGAL NEWS
INCLUSION ALLOWANCE (ADI) AND TRAINING AND EMPLOYMENT SUPPORT (SFL)
Art. 1, par. 198
For Adi beneficiaries, the maximum ISEE is raised to EUR 10,140. On the other hand, with regard to the Support for Training and Work (SFL), the law raises from 6,000 to 10,140 euro per year both the maximum family ISEE value and the family income threshold necessary to access the measure (multiplied by the ISEE equivalence scale).
PENSION FLEXIBILITY
Art. 1, par. 174
Quota 103: The possibility of accessing the flexible early retirement pension, known as ‘Quota 103’, is extended for workers who have reached, by 31 December 2025, an age of at least 62 years and a contribution period of at least 41 years.
Art. 1, par. 173
Women’s Option: for female workers who, by 31.12.2024, have accrued contribution years equal to or exceeding 35 years and a minimum age of 61 years reduced by one year for each child up to a maximum of 2 years.
DECONTRIBUTION FOR WORKING MOTHERS
Art. 1, par. 219 – 220
As from 01.01.2025, female employees as well as self-employed female workers who receive at least one of their incomes are granted a partial exemption from contribution rates for the portion of Ivs contributions to be borne by the female worker. The extent of the contribution exemption will be determined by 31.01.2025 by a Decree of the Minister of Labour and the MEF.
HIRING FACILITATIONS
REFINANCING OF BONUSES FOR YOUNG PEOPLE, WOMEN AND SEZS
Art. 1, par. 44
For the youth bonus, the measure grants private employers who, from 01.09.2024 and until 31.12.2025, hire non-managerial staff under 35 (never employed on a permanent basis) with an open-ended employment contract, for a maximum period of 24 months, exemption from the payment of 100 per cent of the total social security contributions payable by private employers (excluding INAIL premiums and contributions), up to a maximum amount of €500 on a monthly basis for each worker. In the case of recruitment at a head office or production unit located in the regions of Abruzzo, Molise, Campania, Basilicata, Sicily, Apulia, Calabria and Sardinia, the exemption is granted up to a maximum amount of EUR 650 on a monthly basis for each worker.
For the women’s bonus, the measure grants exemption, for a maximum period of 24 months, of 100 per cent from the payment of social security contributions payable by private employers up to a maximum amount of €650 on a monthly basis (excluding INAIL premiums and contributions), for each female employee, hired on an open-ended contract:
– women of any age, without regular paid employment for at least 6 months, resident in the regions of the Single Special Economic Zone for the Mezzogiorno;
– women of any age without regular paid employment for at least 24 months, wherever residents.
The exemption does not apply to domestic work and apprenticeship relationships.
For the ZES (Single Special Economic Zone for the Mezzogiorno) bonus, the measure provides for the exemption, for a maximum period of 24 months, of 100 per cent from the payment of social security contributions due by the private employer up to a maximum of EUR 650 on a monthly basis (excluding INAIL premiums and contributions), for each employee hired as a non-executive, permanent employee, from 1 September 2024 and until to 31 December 2025. The exemption is only granted to private employers employing up to 10 employees in the month in which the employee for whom the exemption is requested is hired.
In addition, the employee must:
– be at least 35 years of age; – have been unemployed for at least 24 months;
– be employed at an office or production unit located in the SEZ.
NEW SOUTHERN DECONTRIBUTION
Art. 1, par. 406 to 422
For the years 2025-2029, a new tax relief is introduced for companies employing workers in southern Italy. The relief consists in an exemption from the payment of employers’ social security contributions, excluding premiums and contributions due to INAIL. The tax relief is available to employers, with the exception of the agricultural sector and domestic work contracts, who employ permanent workers (excluding apprenticeships) in the regions of Abruzzo, Molise, Campania, Basilicata, Sicily, Apulia, Calabria and Sardinia. In the case of private employers with more than 250 employees, the exemption is granted on condition that the employer demonstrates on 31 December of each year an increase in the number of open-ended employment relationships with respect to the previous year.
OTHER INNOVATIONS
CATASTROPHIC POLICY OBLIGATION
Art. 13 Decree-Law no. 202/2024 so-called Milleproroghe
For companies with a registered office and/or permanent establishment in Italy, the obligation to take out insurance policies against damage caused by natural disasters and catastrophic events is extended to 31.03.2025.
Agricultural enterprises and those whose buildings are encumbered by building abuse or lack the required authorisations remain excluded.
However, the implementing decree is still missing.
ATECO CODE CHANGE
With the publication of the ISTAT Communiqué in the Official Gazette (No 302 of 27 December 2024), the new ATECO 2025 classification officially came into force on 1 January.
DEFERMENTS OF UP TO 120 INSTALMENTS
Legislative D. No. 110 of 29 July 2024
A deferment of a maximum of 120 instalments is envisaged for instalments of sums entered on the tax rolls, requested from 01/01/2025 for amounts below €120,000.00 and regardless of the date of request for amounts above €120,000.00, documenting the state of economic difficulty.
EXTENSION OF DEADLINE FOR SPECIAL AMNESTY
31/03/25 is the deadline, for Isa subjects who have entered into the two-year arrangement with creditors, to access the so-called ‘special tax amnesty’ referred to in Article 2-quater of Law Decree 113/2024 for the years from 2018 to 2022, by paying the substitute tax of income tax and related surcharges as well as the regional tax on production activities, in a single instalment or in 24 instalments, the first instalment of which must be paid within this deadline.
The Agenzia delle Entrate also clarified some aspects on the compilation of the income and IRAP forms and on F24 in case of payment by the partner.
For further information or specific advice, our firm is at your disposal.