Biennial Preventive Agreement (CPB) - Facilitated settlement for the financial years 2018 to 2022

With regard to the Biennial Preventive Arrangement (CPB) illustrated in the previous circular, we would like to point out that, upon the conversion into Law of the D.L. 113/2024 (Omnibus Decree), which took place on 9 October 2024, it was also introduced the possibility to define and regularise, on a facilitated basis, the income not declared in the tax periods between 2018 and 2022 by ISA subjects (therefore, flat-rate subjects are excluded) who will adhere to the CPB for 2024-2025, by paying a substitute tax of income tax, related surcharges and IRAP on the higher income, determined according to their ISA score.

In particular, the taxable base of the substitute tax on income tax and related surcharges is constituted, on a lump-sum basis, by the difference between the business or self-employment income already declared in each year and the value of the same increased to the extent of:

1. 5% for subjects with an ISA score of 10;
2. 10% for subjects with an ISA score of 8 or more and less than 10;
3. 20% for subjects with an ISA score of 6 or more and less than 8;
4. 30% for subjects with an ISA score of 4 or more and less than 6;
5. 40% for subjects with an ISA score of 3 or more and less than 4;
6. 50% for subjects with ISA scores below 3;

while the taxable base for the IRAP substitute tax is the difference between the value of net production already declared in each year and the value of the same increased to the extent set forth above.

Once the increased tax base has been calculated in the manner indicated, the substitute tax on income tax and related surcharges is applied at the rate of:

1. 10%, if in the single tax period the ISA grade is 8 or more;
2. 12%, if in the individual tax period the ISA grade is 6 or more but less than 8;
3. 15%, if in the single tax period the ISA grade is less than 6;

while the substitute tax for IRAP is 3.9%.

However, we would like to point out to everyone that the adhesion to the Biennial Preventive Arrangement for ISA subjects entails the extension to 31.12.2025 of the deadlines for tax assessments that would have expired on 31.12.2024; furthermore, for ISA subjects who also adhere to the special amnesty for one or more years between 2018 and 2021, the deadlines for assessments would all be extended to 31.12.2027.

While remaining at your disposal for any doubts or requests for clarification, we would like to take this opportunity to extend our best regards to all.