Regularization of tax bills

Giulio Tedeschi Giulio Tedeschi
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Below are the changes introduced with the provision on the regularization of tax bills (so-called “rottamazione cartelle”) (art. 6, Law Decree n. 193 dated 22/10/2016 – Official Gazette n. 249 dated 24/10/2016).

Subjects concerned

All those subjects who received tax bills by the tax collector's office related to unpaid taxes and contributions from 2000 to 2015.

Those taxpayers who obtained a payment by instalments will have to demonstrate the regular fulfilment of payments from 01/10/2016 to 31/12/2016.

If a legal action was started before the Tax courts, the taxpayer shall give up the proceedings.

Scope of the provision


  • Import VAT
  • Recovery of State aid
  • Sentences by the Court of Audit
  • Fines and penalties due subsequently to criminal sentences and sanctions
  • Fines for violation of the rules of the road

Object of the regularization

The benefit from the regularization implies the payment of the taxes and contributions due, minus delay interest, penalties, and additional amounts.

Therefore, the amount to be paid is: principal, accrued interest due to the tax collector’s office, and reimbursement of expenses.

Fulfilments to obtain the regularization

An application shall be filed by 23/01/2017.

Such application must contain a waiver of legal proceedings.

It allows the interruption of executive procedures towards the concerned taxpayer.

Equitalia (the Italian tax collector’s office) will notify the amounts due and the relevant due dates by 24/04/2017. The deadline for the payment of the last instalment is 15/03/2018.

Payment must be fulfilled by 15/03/2018.

Additional remarks

The provision is effective starting from the publication date of the Law Decree (i.e. 24 October 2016).

However, there could be some changes due to the conversion of the Law Decree at hand into law (to be realized within 60 days after its coming into effect).

Therefore, we suggest:

  • to take stock of the individual situation
  • to contact and meet one of our professionals in order to analyse the situation and define the possible actions to be taken.