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Fiscal Omnibus Decree: Upcoming Changes to Company Cars and VAT, and the Latest Requests for Amendments

The draft corrective legislative decree known as the “Omnibus” decree, part of Italy’s tax reform, is continuing its parliamentary process. Preliminarily approved by the Council of Ministers on 10 June 2026, it consists of 27 articles addressing personal income tax (IRPEF), corporate income tax (IRES), VAT, inheritance tax and excise duties, and was submitted to Parliament on 21 July. The text is now being examined by the Finance Committees, which must issue an opinion before final approval, expected after the summer recess.

Among the most debated measures is the new treatment of fringe benefits for company cars under Article 2. The calculation method remains flat-rate, based on ACI tables and differentiated according to the vehicle’s fuel type. The main change is that, once the vehicle is more than five years old, its taxable value increases by 50%. This increase also applies if the vehicle is subsequently assigned to a different employee. In addition, a 5% surcharge is introduced for optional equipment not included in the ACI tables.

The rules on dependent family members also change under Article 1. The corrective decree removes the cohabitation requirement, or alternatively the requirement to receive maintenance payments not resulting from a court order, for “other family members” identified by Article 433 of the Italian Civil Code, such as siblings, parents-in-law and grandparents, whenever a tax provision refers generally to the family members listed in Article 12 of the Italian Income Tax Code (TUIR), as in the case of corporate welfare. The requirement remains in place, however, where the provision expressly requires the person to qualify as a tax-dependent family member. The amendment corrects an unintended effect of the previous corrective decree, Legislative Decree No. 192/2025, and applies retroactively from the 2025 tax period.

On the VAT front, Article 12 extends the deadline for claiming input VAT deductions until the VAT return for the second year following the year in which the invoice was received, rather than the same year. This significantly broadens the time available to taxpayers.

For professionals, Article 3 introduces a 26% substitute tax on positive gains arising from the sale or offsetting of subsidised tax credits, including those linked to the Superbonus. These gains will be classified as self-employment income. Article 9 also amends the rules governing contributions of shareholdings with unrealised losses, a change expected to affect corporate restructuring transactions.

The text, however, is not yet final. In recent days, Assonime published comments in a document dated 28 July, asking the Finance Committees to introduce a number of amendments. The most important concerns the new VAT deduction rules: the decree does not clarify how invoices received before the new rules enter into force should be treated. Assonime is therefore requesting explicit transitional provisions to avoid disputes involving taxpayers who registered invoices late while relying on the previous, shorter deadline.

With the decree rewriting the rules and trade associations calling for further changes, the Omnibus process is far from complete. Professionals and businesses should therefore closely monitor the outcome of the parliamentary opinions before treating the new provisions as final.

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