The 2026 Budget Law (Law No. 199 of 30.12.2025 – Official Journal no. 301 of 30.12.2025) includes a wide range of tax measures.
Below is a brief summary of the main changes affecting businesses:
- Reintroduction of tax-favored asset assignments and transfers to shareholders, as well as conversion into a simple partnership;
- Abolition of the option to spread capital gains over instalments (subject to limited exceptions);
- Reopening of the extraordinary step-up (tax revaluation) of reserves and funds under tax suspension;
- Targeted changes to the dividend exemption and the participation exemption,with minimum participation or tax value thresholds and implications for EU/EEA withholding taxes;
- Reopening of the preferential settlement of tax liabilities entrusted to the Tax Collection Agent until 31.12.2023 (“Rottamazione quinquies”);
- Reduction of the threshold relevant for the purposes of the prohibition on offsetting in the presence of overdue tax debts via the F24 form;
- Introduction of a withholding tax on B2B payments starting in 2028;
- Increase in the substitute tax applicable to the revaluation of shareholdings;
- Reintroduction of hyper-depreciation for new Industry 4.0 assets and for tangible assets used to produce renewable energy for self-consumption;
- Introduction of a tax credit for energy-intensive businesses linked to Industry 4.0 investments made in 2025;
- Creation of a fund for 2026 to strengthen business support measures, potentially including an increase in the limits of the Industry 4.0 tax credit for investments by 31.12.2025.
In addition, the Milleproroghe Decree Law 2026 (Decree Law no. 200 of 31.12.2025 – currently undergoing parliamentary conversion) extends the option for companies to hold shareholder meetings in a “simplified” manner.
NB: This summary is provided for informational purposes only. Our firm remains available for further details and for assessing how these measures may apply in specific cases.
