A proposed tax amnesty scheme designed to help self-employed workers in Italy resolve past tax liabilities will not proceed after an amendment was withdrawn from legislative review, leaving thousands of partite IVA (VAT-registered sole traders) without the financial relief they'd anticipated—and with no clear timeline for alternative solutions.
Why This Matters:
• No special tax settlement for self-employed workers joining the 2026-2027 concordato preventivo biennale (two-year preventive agreement).
• Years 2020-2024 would have been covered by the withdrawn amnesty proposal, allowing regularization of past underpayments at reduced rates.
• Government pledges to find a workaround, but no concrete legislative path exists yet—meaning planning is difficult for freelancers and small business owners.
What This Means for Self-Employed Workers
For Italy's 3.8 million partite IVA—freelancers, consultants, artisans, and micro-enterprises—the withdrawal of the proposed amnesty is a significant setback. Many were hoping to use it to settle outstanding liabilities from the pandemic years and beyond, particularly those with low ISA scores (between 1 and 6) who face heightened scrutiny from the Agenzia delle Entrate (Italy Revenue Agency).
Understanding ISA Scores: The ISA (Indici Sintetici di Affidabilità, or Synthetic Reliability Indices) are benchmarks that measure your business reliability based on sector performance data. Lower scores between 1-6 indicate your business performs below sector averages, which triggers more intensive tax authority scrutiny and audit risk. Higher scores provide greater confidence with revenue authorities.
The concordato preventivo biennale itself remains in place. Introduced by Legislative Decree 13/2024, the scheme allows ISA-eligible taxpayers to pre-agree their taxable income with the tax authority for a two-year period. In exchange, they gain access to benefits equivalent to a perfect ISA score of 10, and the Revenue Agency's audit powers are significantly curtailed—no analytical or inductive assessments are permitted during the concordato period.
But without the proposed amnesty, taxpayers with past irregularities cannot "reset" before entering the concordato. That means unresolved issues from 2020-2024 may still trigger audits or penalties outside the concordato's protection.
Practical Steps for Residents:If you're self-employed and considering the concordato before the October 31 deadline, experts recommend consulting a commercialista (tax professional) to assess your specific situation. Key questions to address: Do you have unresolved tax issues from 2020-2024? If so, what audit risk do those represent, and how would they interact with concordato enrollment? Are there other regularization pathways available through the Revenue Agency? Professional guidance can help you weigh whether enrollment now—without the amnesty safety net—is the right move for your circumstances.
The Withdrawn Proposal
The amendment, spearheaded by Senator Claudio Lotito of the center-right Forza Italia party, was pulled from the so-called DL Accise ter (Excise Tax Decree) during Senate committee review. The measure would have reopened a ravvedimento speciale—a special voluntary disclosure regime—for taxpayers enrolled in the ISA framework who agreed to enter or renew the concordato preventivo biennale covering tax years 2026-2027.
Under the proposed provision, qualifying taxpayers could have regularized fiscal discrepancies from 2020 through 2024 by paying a substitute tax on notional income, calculated according to their ISA score. The proposed rates ranged from 10% to 15% for income taxes (IRPEF for individuals, IRES for corporations), plus a flat 3.9% regional production tax (IRAP). For the pandemic-affected years of 2020 and 2021, the proposal included discounted rates to account for economic disruption.
Payment would have been due between January 1 and March 15, 2027, giving businesses breathing room to budget.
Why the Financing Fell Through
The Italian Senate Finance Committee, chaired by Massimo Garavaglia of the Lega party, flagged the amendment for lacking copertura finanziaria—budgetary coverage. In plain terms, the proposed tax breaks would have reduced state revenue without identifying offsetting cuts or new revenue sources to balance the books.
Italy's fiscal rules, reinforced by EU budget monitoring, require that any measure reducing tax collection be matched by equivalent savings or income elsewhere. The Lotito amendment failed that test. Rather than force a damaging vote or trigger a budget breach, Forza Italia withdrew the proposal and converted it into a non-binding ordine del giorno (parliamentary motion), which the government acknowledged and committed to address "in the future."
That commitment, however, is vague. No draft legislation has been tabled, and no timeline has been announced.
Updated Concordato Rules for 2026-2027
The Italy Ministry of Economy and Finance finalized the operational framework for the 2026-2027 concordato. Key changes include:
• Extended enrollment deadline: Taxpayers on a calendar fiscal year now have until October 31, 2026 (or November 2, since October 31 falls on a Saturday) to accept the concordato proposal—aligned with the deadline for filing the Modello REDDITI 2026 tax return. For non-calendar taxpayers, the deadline is the last day of the tenth month following the close of their fiscal year.
• Income cap adjustments: Maximum proposed income increases are now 30% for ISA scores between 6 and 8, and 35% for scores below 6. This aims to protect lower-scoring taxpayers from unrealistic revenue targets.
• Inclusion of hyper-depreciation: Special depreciation incentives (iper ammortamento) are now factored into concordato income calculations, reducing the taxable base for capital-intensive businesses.
• Exclusion of forfettari: Starting in 2025, taxpayers under the regime forfettario (flat-rate regime for small businesses with turnover typically under €65,000) are barred from the concordato. Also excluded: those who failed to file returns in at least one of the three prior years, or who were convicted of serious tax crimes in the past three years.
Software to calculate the concordato proposal is available through the Revenue Agency portal, though updates continue to be released.
What Happens Next
The ordine del giorno now sits in the government's legislative pipeline, but its fate is uncertain. The Italian Cabinet has not allocated funds in the current budget cycle to revive the proposed amnesty, and the 2027 budget law, which typically passes in December, is still months away.
In the interim, self-employed workers face a choice: enroll in the concordato without the safety net of a prior amnesty, or hold off and risk missing the benefits entirely. The Agenzia delle Entrate has made clear that concordato enrollment is optional, but the window closes at the end of October.
Tax professionals across Italy emphasize the importance of careful planning. Decisions made before the October deadline will affect tax positioning for two full years, so professional advice is valuable before committing.
Forza Italia lawmakers continue to lobby for a reintroduction of the measure. Senator Lotito has indicated he will push for inclusion in an upcoming fiscal decree, possibly tied to other tax relief discussions anticipated for late 2026.
For now, the government's position is clear: the amnesty concept has support in principle, but budgetary constraints currently prevent its implementation. Until funding becomes available, partite IVA must make concordato decisions based on their current circumstances and available tax counsel.
