Italy: The main new features of the Milleproroghe Decree

published on 14 March 2025 | reading time approx. 5 minutes

On February 24, 2025, Law No. 15 of February 21, 2025, converting Decree Law No. 202 of December 27, 2024 (so-called “Milleproroghe Decree”) was published in the Official Gazette and came into effect on February 25, 2025.

Main changes introduced by the Milleproroghe Decree 2025

Rottamazione-Quarter: Reinstatement Of Former Beneficiaries

The conversion measure provided for readmission to the rottamazione-quater for taxpayers who had lapsed from the facilitated definition provided for by the Budget Law 2023 (Law 197/2022), due to irregularities in installment payments. Only those who had submitted the relevant application by June 30, 2023, and who, as of December 31, 2024, were forfeited due to non-payment, insufficient payment or late payment of installments, provided that it was beyond the 5-day grace period provided by the original regulations, can be readmitted.

Readmission allows them to benefit again from the facilitated definition that provides for the elimination:

of tax and contribution penalties;
of late payment and late registration interest;
of collection surcharges.

Interested parties must submit a special application for readmission by April 30, 2025, using the forms prepared by the Revenue Agency. It is possible to opt for a lump sum payment or in up to 10 installments, with due dates set for July 31, 2025, Nov. 30, 2025, and every Feb. 28, May 31, July 31 and Nov. 30 thereafter until 2027.

Offsetting the payments against any tax credits remains precluded, and interest at the annual rate of 2 percent is charged on the deferred amounts as of Nov. 1, 2023. Enforcement and precautionary actions (lien etc.) remain suspended, with the understanding that those already initiated are not automatically cancelled, unless a successful auction sale has taken place.

Tax Returns 2025

The deadline for the approval and publication of tax returns for the 2024 tax year, including the PF, SC, SP and ENC models, the IRAP model, the CNM model, the 730 model and the 770 model, is extended to March 17, 2025.

As a result, the initial deadline for submitting income and IRAP returns for the year 2024 will shift to April 30, 2025, with no changes to the final deadline, which is confirmed as Oct. 31, 2025.

Extension of the E-Invoicing Ban for Healthcare Services

The ban on issuing electronic invoices (Art. 10-bis of Decree Law 119/2018) via the Interchange System (SdI) is extended to Dec. 31, 2025 (Art. 3 co.6) for:

those required to send data to the Sistema Tessera Sanitaria;
entities not subject to the TS System but issuing invoices for healthcare services rendered to individuals.

VAT Regime for Association Entities

Postponed to January 1, 2026 (Art. 3 co. 10) the entry into force of the reform of the VAT regime for association entities. Until that date, the VAT exclusion regime will continue to apply for transactions made toward members, associates and card-carrying members, performed in accordance with institutional purposes and for specific consideration or additional contribution.

5 per thousand for non-profit organizations

Extended to Dec. 31, 2025 (Art. 12) the transitional regime that allows NPOs registered as of Nov. 22, 2021, to continue to be eligible to receive the 5 per thousand according to the rules for voluntary organizations, even if they are not registered at the RUNTS.

Extension of IMU and Municipal Tax Deadlines

Resolutions approving IMU rates and regulations for 2024 are valid if they are entered in the Fiscal Federalism Portal by November 30, 2024 and published on the website of the Department of Finance by February 7, 2025. For any tax differences, payment without penalty and interest is possible until February 28, 2025. In case of lower IMU due than already paid, a refund is due according to ordinary rules (ar. 1 co. 164 of Law 296/2006).

For noncommercial entities with exempt properties, the deadline of June 16, 2025 for the third IMU installment for 2024 remains confirmed.

Remote Corporate and Association meetings

Paragraph 14-sexies of Art. 3 of DL 202/2024, introduced during conversion, restates until Dec. 31, 2025, the time limits for applying the emergency rules on assemblies of companies, associations and foundations, initially provided for by DL 18/2020.

Until that date, it will be possible for meetings held (not just convened):

in SPAs, SAPAs, SRLs, cooperative and mutual insurance companies, allow electronic or postal voting and remote participation, even in derogation of the statutes.
conduct meetings entirely remotely, ensuring the identification and participation of members, without requiring the chairman, secretary or notary to be physically in the same place.
in SRLs, also allow voting by written consultation or consent expressed in writing, derogating from the ordinary rules.
providing, for some companies (such as listed companies), mandatory participation through the designated representative.

Transition 5.0 Tax Credits

Confirmed the possibility to benefit from the Transition 5.0 tax credit also for investments made on or after January 1, 2024, even if made before the formal submission of the application for access.

Simplified Logistics Zones (ZLS)

Extended to Nov. 15, 2025, the deadline for making subsidized investments in ZLSs. Interested economic operators must:

send a prior communication to the Revenue Agency from May 22 to June 23, 2025, indicating the eligible expenses already incurred and planned;
submit a supplementary communication from Nov. 20 to Dec. 2, 2025, with the actual expenses incurred.

Extension for ISA and CPB software

DL 202/2024, in Article 3-bis paragraph 5, postponed to April 30, 2025 the date by which the Revenue Agency must make available software for:

the preparation and submission of ISA forms for the 2024 tax period;
the formulation of the proposed two-year composition with creditors for the period 2025-2026.

This extension only concerns the availability of the computer programs, while the deadline for joining the two-year composition with creditors for entities with fiscal year coinciding with the calendar year remains confirmed to July 31, 2025.

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