We would like to remind everyone that, as of 1 March 2026, commissions received by travel and tourism agencies, agents, recommenders and maritime and air brokers, will be subject to the withholding tax provided for in Article 25-bis of Presidential Decree 600/1973.
In particular, Article 1, paragraphs 140-142, of the Budget Law 2026 (Law No. 199/2025) eliminated the withholding exemption regime provided for by Article 25-bis, paragraph 5, of Presidential Decree No. 600/1973, which remains applicable for the commissions listed above paid until 28.02.2026.
Recall that the withholding tax in question is ordinarily applied at the rate of half of the first income bracket for IRPEF purposes (currently equal to 23%), i.e. the’11,5%, of the commissions paid; if, in the exercise of his activity, the agent makes use, on a continuous basis, of employees or collaborators, the withholding shall be equal to the 4,6% (20% of 23%).
The payment of the reduced withholding tax of 4.6% is, however, conditional on the recipient submitting a declaration stating that he/she meets the requirements.
We specify that this withholding continues to not levy on commissions received by authorised retailers of travel documents relating to the carriage of persons, who buy and sell tickets in its own name and on its own behalf, without accruing any commission, since it is precisely the purchase and sale of tickets.
All persons paying such commissions are obliged to withhold tax, excluding:
- tax representatives for VAT purposes of foreign entities (Article 17(3) of Presidential Decree 633/72), which do not have a permanent establishment or fixed base in Italy;
- intra-EC operators (or from non-EC States with which adequate administrative cooperation instruments exist), who have been allocated an Italian VAT number (so-called direct identification, provided for in Article 35 of Presidential Decree 633/72), without a permanent establishment or fixed base in Italy;
- persons under the flat-rate scheme under Law 190/2014;
- persons without a VAT registration number.
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.