As every year, we remind you that articles 6 to 22 of Legislative Decree no. 13 of 12 February 2024, as subsequently amended and supplemented, have provided for the possibility for ISA taxpayers to access the Two-Year Preventive Agreement (CPB). by 31 October 2026.
The Biennial Preventive Arrangement is a proposal made by the Inland Revenue Agency to define in advance and on a lump-sum basis business or self-employment income and, where payable, the net value of production for IRAP purposes for the 2026-2027 two-year period, regardless of actual income earned, barring specific exceptions.
Access to the CPB is permitted to taxpayers required to apply the ISAs for whom the exclusionary conditions provided for by the CPB decree do not occur and, in particular, taxpayers who: will not be able to join.
- they started their business from 2025 onwards;
- they have debts for taxes administered by the Revenue Agency or social security contributions that have been definitively assessed, totalling €5,000.00 or more as at 31.12.2025, unless they have been brought below this threshold or paid by instalments by the deadline set for accession;
- have not filed a tax return for at least one of the three tax periods preceding those in which the arrangement applies, where there is an obligation to do so;
- they have received convictions for offences set out in Legislative Decree No 74/2000, Article 2621 of the Civil Code, as well as Articles 648-bis, 648-ter and 648-ter 1 of the Criminal Code (tax offences, false corporate communications, money laundering / self-laundering, use of money, goods or assets of illicit origin, or where there has been a plea bargain for the same offences), committed in the last three tax periods preceding those of the application of the composition with creditors;
- they earned exempt, excluded, or non-competing income exceeding 40 per cent of the income derived from the exercise of a business, art or profession in the tax period preceding those to which the proposal refers;
- in 2026 they joined the flat-rate scheme or, in the case of entities or companies, are involved in merger, demerger, contribution of a business or business branch operations, or, only in the case of simple partnerships, limited partnerships (Sas), general partnerships (Snc), shipping companies, de facto companies or professional associations without legal personality, there has been an increase in the number of partners or associates, except in specific cases;
- in 2025 they declared professional income and at the same time participated in professional associations, partnerships between professionals or law firms carrying out economic activities attributable to the same ISA, unless the association, STP or STA adheres to the CPB for the same two-year period;
- in the case of professional associations, STPs or STAs, if all the members/associates who earn self-employment income attributable to the same ISA do not also participate.
With respect to ISA taxpayers who have adhered to the settlement, for the tax periods subject to the settlement, the assessments provided for by Article 39 of Presidential Decree No 600/1973 (analytical, analytical-inductive and pure inductive or extracontinuing assessments) may not be carried out, unless, following the investigative activity of the Tax Administration, one of the grounds for forfeiture of the CPB applies.
The ISA reward benefits are also applicable, including the exclusion of tax assessments based on simple presumptions pursuant to Article 9-bis, paragraph 11, of Decree-Law No. 50/2017.
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.