As announced in our Circular No. 5/2023, tax returns up to and including that for the tax period current as at 31 December 2021 may be corrected on preferential terms by way of a special voluntary correction (“ravvedimento operoso speciale”), by filing a subsequent return and paying the taxes together with interest and penalties by 31 March 2023; the administrative penalties are exceptionally reduced to 1/18 (one eighteenth) of the minimum penalty. The amounts due may be paid by way of a single payment or in 8 quarterly instalments, whereby interest of 2% p.a. accrues on such payment by instalments. It is necessary that a valid tax return has been filed for the tax periods to be remedied; otherwise the conditions for a subsequent filing are not met.
Circular No. 2/E of 21 January 2023 published the first guidance on the special voluntary correction, and Decree No. 6/E of 14 February 2023 additionally established specific payment codes for the subsequent payment of interest and penalties by means of form F24. It should be noted that the taxes themselves must be paid using the usual payment codes; specific codes are provided only for the interest and penalties due. Below is an overview according to the decree of 14 February 2023, whereby it must be noted that a strict distinction has to be made between the interest arising from the settlement itself and that arising from any payment by instalments:
| Payments for the special voluntary correction under Art. 1, paras. 174 to 178 | ||||||
| F24 section | Payment code for penalty | Region/municipality field | Payment code interest | |||
| F24 section | Payment code for penalty | Region/municipality field | Interest on the voluntary correction | Interest on instalments | ||
| Erario | TF45 | IRPEF | --- | 1989 | 1668 | |
| Erario | TF46 | IRES | --- | 1990 | 1668 | |
| Erario | TF47 | VAT | --- | 1991 | 1668 | |
| Erario | TF48 | Surcharges on IRES | --- | 1990 | 1668 | |
| Erario | TF49 | Substitute taxes and similar levies | --- | 1992 | 1668 | |
| Region | TF50 | IRAP | Region code | 1993 | 3805 | |
| Region | TF51 | Regional IRPEF surcharge | Region code | 1994 | 3805 | |
| IMU and other local levies | TF52 | Municipal IRPEF surcharge | Municipal cadastral code | 1998 | 3857 | |
| Erario | TF53 | Withholding taxes | --- | Added to the withholdings. | 1668 | |
| Regions | TF54 | Withholding of regional IRPEF surcharge | Region code | Added to the withholdings | 3805 | |
| IMU and other local levies | TF55 | Withholding of municipal IRPEF surcharge | Municipal cadastral code | Added to the withholdings | 3857 | |
| Erario | TF56 | Other tax offences | --- | 1992 | 1668 | |
No cumulation of penalties:
Attention must be paid to the penalties arising from repeated offences: in the case of tax assessment notices in which multiple errors of the same kind are established, the penalty is applied only once, increased by one quarter (so-called “legal cumulation”). This relief applies, however, only where the penalty is determined by the Italian Revenue Agency, and not in the case of voluntary corrections. Where the administrative penalty is imposed by the tax office by means of an assessment notice, the aforementioned cumulation may by contrast be applied:
In cases where one is already aware of ongoing investigations and such repeated offences exist, one solution could therefore be to invite the office to serve, for its part, an invitation to settlement on preferential terms by 31 March 2023. Cumulation then applies again, and 1/18 is applied to the cumulated penalty.
Recommendation: should you be aware of errors from recent years for which, in extreme cases, informal investigations are already under way and which should be remedied accordingly, please contact us without delay so that the appropriate measures can be discussed.
Please do not hesitate to contact us if you have any queries.
Yours faithfully,
Dott. Comm. Josef Vieider
Newsletter
Our newsletters – Useful Updates on Tax and Legal Matters
13.08.2026, Newsletter No. 35/2026
Corrective decree to the tax reform of 7 August 2026 – other changes
Legislative Decree No. 148 of 7 August 2026 introduces numerous further corrections to the tax reform – from income from employment to business and financial income, from VAT to tax assessment and the two-year advance agreement.
12.08.2026, Newsletter No. 34/2026
Corrective decree of 7 August 2026 and its effects on the mixed use of company cars
The corrective decree of 7 August 2026 (Legislative Decree No. 148/2026) standardises the calculation of the benefit in kind for the mixed use of company cars with retroactive effect from 1 January 2026 and at the same time introduces two new surcharges on the benefit-in-kind value.