Italy biennial preventive tax agreement 2026-2027

The Biennial Preventive Agreement (Concordato Preventivo Biennale) for the 2026-2027 period allows eligible Italian businesses and professionals to pre-determine their taxable income for two years. Under this mechanism, tax authorities propose an income base using tax returns and Synthetic Indices of Tax Reliability (ISA) data. While taxpayers can accept or reject these proposals, they cannot negotiate specific amounts. Once accepted, taxes are paid based on the agreed amount regardless of actual economic performance; surplus profits are not taxed, but taxpayers must pay the full agreed amount even if actual profits are lower.

Following the initial framework, the Italian Revenue Agency (Agenzia delle Entrate) issued Circular No. 8/E to provide specific implementation guidelines. This guidance introduced new limits on proposals based on ISA scores. Specifically, proposals cannot exceed certain percentages of previously declared income: 10% for a score of 10, 15% for scores between 9 and 10, 25% for scores between 8 and 9, and 30% for scores between 6 and 8. The deadline for formalizing the choice was set for November 2, 2026.