Italian 2026 Finance Law – Key Tax Measures: Reduced Tax Rate for Middle Incomes | Flat-tax/HNWI“new-resident” regime adjustments (for high net-worth individuals) | Incentives / “flat tax” regimes for employment income| Continued incentives for investments and capital goods (businesses) | Tax-collection and “fiscal-relief” measures: debt-collection amortization, freeze for property-transfer taxes | Tax treatment of dividends, capital gains, and financial income | Sectors/Special Taxes: financial intermediaries, “windfall” taxes, bank levy

Tax Updates

Contents of this Post

Italian 2026 Tax Update

Background

The legisaltive scene has been dominated by the continuing implementation of the Italian tax reform programme launched under the 2023 enabling law,  Law No. 111 of 9 August 2023

Overall, 2026 has been characterised less by radical new taxes or changes, and more by the systematic reorganisation, consolidation and refinement of Italy’s tax legislation in preparation for the next phase of implementation in 2027- Below is a summary of progress so far.The summary by no means cover all measures of a very busy legislature, but focusses on matters of interest to an international clientele. 

Recent Major Legislation

Payments and Collection Consolidated Code

As part of the implementation of the 2023 Tax Reform, (Legislative Decree No. 33 of 24 March 2025) introduced a consolidated code governing tax payments, withholding taxes, refunds, collection procedures and enforced recovery of tax debts. The code reorganises and consolidates previously fragmented legislation into a single statutory text, with the aim of improving the coherence and accessibility of the rules governing tax collection and administration.

Consolidated Registration Tax and Indirect Taxes Code

As part of the implementation of Italy’s 2023 Tax Reform, (Legislative Decree No. 123 of 1 August 2025) introduced a new consolidated code bringing together the legislation governing registration tax and a range of other indirect taxes, including inheritance and gift tax, stamp duty, mortgage and cadastral taxes, and IVAFE. The measure aims to simplify the legislative framework by reorganising and consolidating previously fragmented provisions into a single statutory text.

Consolidated VAT Code

As part of the tax reform programme,  (Legislative Decree No. 10 of 19 January 2026) introduced a consolidated VAT Code (Testo Unico IVA). The new code reorganises and rationalises the legislative provisions governing Italian VAT, bringing together in a single statutory text rules previously scattered across multiple enactments and improving the coherence and accessibility of the VAT framework.

Consolidated Income Tax Code

The publication of the new Consolidated Income Tax Code (Testo Unico delle Imposte sui Redditi) in June 2026 represents one of the most significant milestones. The new text reorganises and codifies existing income tax legislation into a single, more coherent framework. Although primarily a consolidation exercise, it should make the rules easier to navigate from 2027 onwards.

Income Tax Management Code

A Consolidated Code Contianing measure for tax compliance and assessment was published in August 2026 (Legislative Decree No. 141 of 5 August 2026).

This is a consolidated code governing:

  • tax returns and declarations;
    taxpayer obligations and communications;
  • the tax registry (Anagrafe Tributaria);
  • audits and enquiries;
    powers of assessment (accertamento);
  • co-operative compliance;
  • advance pricing agreements and international rulings;
    taxpayer-administration cooperation mechanisms.

Omnibus Decree

August 2026 saw publication of the “Omnibus” corrective decree, introducing a broad package of adjustments across several areas of taxation. The decree contains measures affecting income taxes, VAT, succession and gift taxes, tax compliance procedures and the cooperative compliance regime, together with further refinements to the broader tax reform programme.

Taxation of Financial investment income

The Italian Government has indicated that further work is envisaged on rationalising the taxation of financial income and capital gains. A final consolidated Financial Investment Income Code has yet been enacted.

Guidance

The Italian Tax Agency has also continued to issue implementing guidance and clarifications on measures introduced during the tax reform process, reflecting the practical challenges of applying the new rules and providing greater certainty for taxpayers and advisers.

Guidance Date Subject
Circular No. 20/E/2024 4 November 2024 Comprehensive guidance on the new tax residence rules introduced by Legislative Decree No. 209/2023. The circular explains the revised concepts of domicile and tax residence, the new physical presence test, and the rules applicable to companies and other entities.
Circular No. 4/E/2025 16 May 2025 Guidance on the income tax reforms introduced by the 2025 Budget Law and implementing tax reform legislation, including revised IRPEF rates and bands, employment income taxation, employee benefits and related measures.
Circular No. 9/E/2025 24 June 2025 Updated guidance on the Concordato Preventivo Biennale (CPB) regime for 2025-2026, including eligibility requirements, access procedures, causes of exclusion and termination, tax effects and operational aspects of the regime.
Circular No. 6/E/2026 6 August 2026 Comprehensive guidance on the reformed Cooperative Compliance (Adempimento Collaborativo) regime, including expanded access, Tax Control Framework certification, enhanced incentives and practical application of the new rules.

Law No. 111 of 9 August 2023 (the Italian Tax Reform Enabling Law)

This law delegated authority to the Italian Government to modernise and reform significant parts of the Italian tax system through a series of legislative decrees. The law set out broad guiding principles rather than detailed rules, with objectives including simplification of the tax framework, greater legal certainty, improved relations between taxpayers and the tax authorities, enhanced international competitiveness, and the reorganisation and consolidation of tax legislation into clearer, more accessible texts

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