- Italy’s tax agency (Risoluzione No. 38 of 23 Oct. 2026) has issued tax codes needed to apply “giuridic cumulation” when using voluntary disclosure/penalty relief (ravvedimento operoso).
- Under the amended rules, the reduced penalty is calculated based on the first violation, and the unified penalty may be computed using procedures made available by the tax agency.
- Cumulation remains limited to one tax and one tax period: penalties for income taxes and VAT cannot be combined if they stem from the same violation, and repeated violations across different years cannot be aggregated; it is also not allowed for late payments or undue offsetting.
- Typical cases where cumulation can apply include omission of invoicing with VAT underreporting, export-related violations with VAT underreporting, and failure to withhold tax with an inaccurate Form 770.
- Some violations are expressly excluded from cumulation in voluntary disclosure, including failures to transmit telematic receipts/corrispettivi that do not affect VAT settlement and late/missing transmission of Certificazioni Uniche.
Source: eutekne.info
Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.
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