With its publication in the Official Journal on 17.06.2025, the decree law approved by the Council of Ministers on 12.06.2025 (no. 84/2025 – the “Decree” or “DL”) comes into effect. The Decree addresses various aspects of tax legislation, introducing amendments designed to simplify, correct, and coordinate recent changes introduced in recent months.
Here are some of the most significant developments for businesses and beyond:
The Decree modifies the rules on the carry-forward of losses in extraordinary operations. To determine the amount of carry-forward losses, contributions and payments made in the previous 24 months will now be counted at double their value, simplifying the calculation process.
Key updates have also been made to the CFC rules: the minimum foreign national tax will now be considered when calculating the effective tax rate of a subsidiary. Additionally, changes have been introduced to the optional mechanism that allows foreign subsidiaries to determine their effective taxation by paying 15% on their profits.
There is also confirmation of the postponement of tax payment deadlines (income tax, IRAP, and VAT) for ISA and flat-rate taxpayers in 2025: the standard deadline of 30 June is extended to 21 July, with an option to pay by 20 August with a 0.4% increase.
For hybrid misalignments, the transitional period has been abolished. The deadline for submitting the required documentation is now aligned with that of the income tax return for the 2024 tax year – namely, by 31 October 2025.
On the VAT front, the extension of the reverse charge mechanism to freight transport contracts has been confirmed. This will apply to all services carried out through procurement, subcontracting, assignment to consortium members, or other business relationships, provided they are rendered to companies involved in freight transport, handling, and logistics. This provision is subject to specific EU authorization. In the meantime, suppliers and clients may opt for the client to pay the value added tax in the name and on behalf of the supplier, who remains jointly liable for the tax due.
There is also an update regarding the split payment mechanism: transactions involving FTSE MIB companies will no longer be subject to this rule for invoices issued from 1 July 2025.
Studio Tributario Deiure is available to provide further information and practical support for the implementation of the new tax measures.
