Italy Omnibus Decree updates tax credit and VAT rules

The Omnibus Decree (Legislative Decree 148/2026) introduces significant changes to tax treatments for self-employed professionals and VAT procedures in Italy.

Under the new regulations, positive differentials resulting from the sale or compensation of purchased tax credits are now classified as self-employment income. These differentials, which occur when credits are acquired at a value lower than their nominal amount, will be subject to a 26% substitute tax. This regime applies to credits purchased from August 12, 2026, with the possibility of retroactive application starting from 2024. The law covers various types of credits, including those originating from construction incentives.

Additionally, the decree extends the deadlines for VAT deductions and the registration of passive invoices. Taxpayers may now exercise the right to VAT deduction by the tax return relating to the second year following the year in which the right arose. Similarly, passive invoices can be registered by the deadline for the tax return of the second year following their receipt. These changes, effective August 12, 2026, align with principles established by the European Court of Justice.