L. 207/2024
In Ordinary Supplement No. 43 to Official Gazette No. 305 of 31/12/2024, Law No. 207 (Budget Law 2025) was published, effective 1/1/2025.
Below are the main novelties in tax and facilitation matters.
IRPEF reform
The reduction of the taxable income brackets and related IRPEF rates from four to three, already planned for the 2024 tax year, is confirmed.
From the 2025 tax year, the structure of taxable income brackets and IRPEF rates will therefore remain as follows:
- over EUR 50,000: 43%.
- up to 28,000 euro: 23%;
- over 28,000 euro and up to 50,000 euro: 35%;
Tax wedge reduction
New mechanism for reducing the so-called ‘tax wedge’ for employees, which will be tax-only with the recognition of a bonus or an additional deduction.
The bonus is available to workers with a total income of no more than EUR 20,000 and is determined by applying the percentage of the taxpayer’s income:
- 7.1%, if the income does not exceed EUR 8,500;
- 5.3%, if the income is above EUR 8,500 but not EUR 15,000;
- 4.8%, if the income exceeds 15,000 euro.
The additional deduction is available to employees with a total income of between EUR 20,000.01 and EUR 40,000.
The bonus and the additional deduction are granted automatically by the tax withholding agent upon payment of wages.
Deduction for family loads
As of 01/01/2025, a number of changes are made to the rules on IRPEF deductions for family loads, pursuant to Article 12 of the Consolidated Income Tax Act.
The following deductions are abolished:
- for dependent children over 30 years of age who are not disabled;
- for other dependants other than cohabiting ascendants;
- for non-EU citizens with family members abroad.
For the purposes of withholding tax, employees and recipients of income assimilated to employment must promptly notify the tax withholding agent of the details of family members for whom tax deductions are no longer due.
Building renovation
Remodulation of the relief rate (all other provisions remain unchanged).
For owners (or holders of rights in rem) who use the real estate unit as their main residence, the IRPEF deduction applies at the rate:
- 50% for expenditure incurred in 2025, up to a maximum subsidised expenditure limit of EUR 96,000;
- 36% for expenditure incurred in the years 2026 and 2027, up to a maximum subsidised expenditure limit of EUR 96,000.
For all interventions carried out on real estate units other than the main home, within the limit of subsidised expenditure not exceeding EUR 96,000 per real estate unit, the rate is set at:
- 36% for expenditure incurred in 2025;
- 30% for expenditure incurred in 2026 and 2027.
Ecobonus and Sismabonus
The ‘ecobonus’ and ‘sismabonus’ are extended in the following measures:
- for main dwellings, the rate is 50 per cent for expenses incurred in 2025, and drops to 36 per cent for those incurred in 2026 and 2027;
- for property units other than the main dwelling, the rate is 36% for expenditure incurred in the year 2025, falling to 30% for expenditure incurred in the years 2026 and 2027
Reasons for exclusion from the flat-rate scheme
The flat-rate scheme for sole proprietors and self-employed persons is not applicable if income from employment and similar income, as referred to in Articles 49 and 50 of the Consolidated Income Tax Act, exceeds the amount of EUR 30,000. The period to be considered for the calculation of the limit is the year preceding the year in which you intend to enter or remain in the regime.
For the year 2025 only, this threshold is increased to Euro 35,000
Crypto Taxation
On the capital gains and other income referred to in Article 67 co. 1 lett. c-sexies) of the TUIR, realised from 1.1.2026, “the substitute tax referred to in Articles 5, and 6 and 7 of Legislative Decree No. 461 of 21 November 1997 is applied at the rate of 33%.
For 2025, the levy therefore remains at 26%.
Business travel expenses traceability obligation
Only if the relevant payments are made by traceable methods, reimbursements of expenses for travel or missions under Article 51(5) of the Consolidated Law on Income Tax (TUIR) are not included in the employee’s income:
- food
- accommodation
- travel and transport by taxi or hire car with driver.
Entertainment expenses and business gifts
Entertainment expenses and those for gifts become deductible (for the purposes of business income and IRAP tax base) only if incurred by traceable methods (bank or postal payment or by means of debit, credit and prepaid cards, bank cheques and bank drafts).
Reverse Charge for Logistics Procurement
For the provision of services, carried out under contracts and subcontracts, characterised by the prevalent use of labour at the principal’s premises, rendered to undertakings engaged in the transport and handling of goods, the following is provided:
- the application of the reverse charge mechanism, following the issue of a special derogation measure from the VAT Directive by the Council of the European Union;
- on a transitional basis, pending the issuance of this derogation measure, an optional scheme whereby VAT is paid by the principal.
Facilitated assignment of assets to shareholders
The tax benefits accrue for transactions entered into by 30/09/2025 tax are substantiated:
- Substitute taxation of 8% ( 10.5% for companies that have been a shell company for at least two years in the three-year period 2022-2024) on capital gains realised on assets assigned to shareholders, or used for purposes other than the exercise of the enterprise following the transformation;
- the 13% substitute tax on the tax-suspension reserves cancelled as a result of the facilitated transactions.
IRES Premium
For 2025 only, the IRES rate will be reduced from 24% to 20% on declared business income for companies that fulfil the following conditions:
- allocation to reserves of at least 80% of the profits for the financial year 2024;
- investment of a portion of these earmarked profits (amounting in any case to no less than EUR 20,000) in the purchase, including through leasing, of new 4.0 and 5.0 capital goods;
- new hires of permanent employees with increased employment.
PEC obligation for company directors
The obligation to indicate one’s digital domicile at the company registry is extended to directors of incorporated companies.
As of 1 January 2025, therefore, all company directors, if they do not already have one, will be required to activate a certified electronic mail (CEM) address and indicate it to the company register.
With regard to this novelty, however, neither specific deadlines for compliance nor penalties for non-compliance have been set at present.