Italy to reform tax sanctions with new proportionality rules

Italy is implementing a significant reform of its tax sanction system, aimed at moving away from a rigid and punitive model toward one based on proportionality, predictability, and spontaneous compliance. Under the new consolidated text (testo unico) scheduled for January 1, 2027, sanctions will be calibrated based on the severity of the violation and the conduct of the taxpayer.

The reform introduces the principle of offensiveness, meaning that purely formal errors that do not hinder controls or impact tax payments will no longer be punishable. For violations committed from September 1, 2024, taxpayers will benefit from more organized voluntary correction mechanisms (ravvedimento operoso) and lower fixed-rate sanctions.

Specific changes also target regional and local taxes. For violations committed from January 1, 2027, regarding taxes such as IMU, TARI, tourist tax, and short-term rentals, new predetermined measures will apply. These include a 100% penalty for failure to file a declaration and a 40% penalty for inaccurate declarations, with a minimum fine of 50 euros.