Italy implements new tax rules for professional income and credits

New technical regulations in Italy are changing how professional income is determined, specifically regarding the purchase and use of tax credits on the secondary market. Following the reforms introduced by Legislative Decree 192/2024, which established the principle of comprehensiveness for self-employed income, the fourth corrective decree (Legislative Decree 148/2026) addresses the taxation of tax credits.

Under these new rules, when a professional purchases a tax credit to use for compensation or subsequently transfers it, those credits contribute to the formation of professional income. A substitute tax rate of 26 percent will be applied to the differentials, rather than the standard ordinary taxation rate.