Biennial Preventive Agreement 2026-2027 tax rules

The Biennial Preventive Agreement (Concordato Preventivo Biennale) for 2026-2027 allows businesses and professionals subject to Synthetic Indices of Tax Reliability (ISA) to determine their taxable income in advance for a two-year period.

Under this mechanism, the tax authorities propose a taxable income base based on tax returns, ISA data, and other available information. Taxpayers can accept or reject the proposal, but they cannot negotiate the specific amounts. Once accepted, taxes for 2026 and 2027 are calculated based on the agreed income, regardless of actual economic performance. If actual profits exceed the agreement, the surplus is not taxed; however, if profits are lower, the taxpayer must still pay based on the agreed amount.

Key updates for the 2026-2027 period include the exclusion of those under the flat-rate regime (regime forfetario) starting in 2026. The deadline for taxpayers with a calendar year tax period to join is October 31, 2026. The regulation also includes provisions for income reductions in cases of extraordinary or calamitous events and offers benefits for those renewing previous agreements.