Italy Updates Guidance on Concordato Preventivo Biennale Tax Settlement Scheme

Context

The CPB was introduced by Legislative Decree 13/2024 as a voluntary compliance mechanism to encourage transparent disclosure of tax obligations. The scheme allows eligible taxpayers to settle their tax positions for a two-year period, reducing administrative burdens and offering certain compliance incentives. Circular 8/E, published on 6 October 2026 and signed by Agenzia delle Entrate director Vincenzo Carbone, integrates amendments from Legislative Decree 148/2026 (the October 2026 Omnibus decree). It serves as the primary reference document for the 2026–2027 enrollment cycle, replacing earlier guidance.

The CPB is available to taxpayers with business income or income from professional or artistic activities who were subject to Standard Industry Analyses (ISA) for fiscal year 2025. This includes both first-time applicants and those renewing from the prior 2024–2025 biennium. The enrollment deadline for the upcoming cycle was shifted from 31 October to 2 November 2026, as the original date fell on a Saturday.

What's Changing

Circular 8/E introduces several key updates to the CPB framework. Most notably, renewal applicants receive a materially enhanced benefit package relative to first-time participants:

• Exemption from conformity certification (visto di conformità): Up to €100,000 annually for VAT and up to €70,000 for direct taxes and IRAP.
• Exemption from certification or guarantee requirements: For VAT refunds up to €100,000.
• Advance of the statute of limitations: By two years for tax assessment activity.

Renewal applicants may also opt into a back-year settlement regime, paying substitute taxes on income and related surcharges, as well as a substitute IRAP tax, at reduced rates. These provisions aim to incentivize continued participation in the CPB by offering tangible compliance and financial advantages.

Implications for Taxpayers

For IT professionals and businesses operating in Italy, Circular 8/E clarifies the administrative and financial benefits of participating in the CPB. The enhanced incentives for renewal applicants—particularly the exemption from conformity certifications and the advance of the statute of limitations—may streamline compliance processes and reduce administrative overhead. Taxpayers should evaluate whether they meet the eligibility criteria for ISA 2025 and assess the potential benefits of enrolling in or renewing their participation in the CPB.

First-time applicants should note that the benefits package is less favorable than for renewals, making it critical to weigh the costs and benefits of joining the scheme. For those already enrolled in the 2024–2025 biennium, Circular 8/E provides a clear roadmap for renewing participation while taking advantage of the new incentives.

Outlook and What to Watch

As Italy continues to refine its tax compliance frameworks, the CPB remains a key tool for promoting voluntary disclosure and reducing administrative burdens. The integration of Legislative Decree 148/2026 into Circular 8/E underscores the government's commitment to improving the scheme's attractiveness for taxpayers.

Key milestones include:

• 2 November 2026: Enrollment deadline for the 2026–2027 CPB biennium.
• Fiscal year 2025: ISA application period for determining eligibility.
• Legislative Decree 148/2026: Ongoing implementation of amendments introduced by the October 2026 Omnibus decree.

Tax practitioners should monitor any further updates from the Agenzia delle Entrate, particularly regarding the application of back-year settlement regimes and potential adjustments to ISA parameters.