Italy Agenzia Entrate Provvedimenti

Certificazioni Uniche Bulk Data Request Experimental Period Extended

The Agenzia delle Entrate has issued Provvedimento del 20 aprile 2026 extending the experimental period for the massive acquisition of Certificazioni Uniche (CU) tax certification data. The extension applies to the framework originally established by Provvedimento prot. n. 390142 of 20 October 2025, which introduced procedures for the telematic submission of CU data requests and bulk data provision. Technical specifications for the extended period are provided in Annex A (transmission specifications) and Annex B (data provision specifications).

Italian Tax Agency Fiscal Reliability Index Benefits Directive

The Italian Tax Agency (Agenzia delle Entrate) has issued Directive Prot. n. 123160/2026 establishing fiscal reliability index (ISA) thresholds for tax benefits under Article 9-bis, comma 11 of decree-law n. 50/2017. Taxpayers with ISA reliability levels of 8, 8.5, or 9 qualify for benefits including exemption from conformity seals (visto di conformità) for VAT credit compensation up to €70,000, VAT refund guarantees, exclusion from non-operating company rules, and reduced assessment limitation periods. The directive applies starting from tax period 2025.

IRAP Refund Model for Intra-EU and SEE Dividends Exceeding 5% Threshold

The Agenzia delle Entrate has issued a provvedimento implementing Article 1, paragraphs 48 and 49 of Law 30 December 2025, n. 199, approving an official application form (model) for taxpayers to request refunds or use in compensation the portion of IRAP attributable to intra-EU or EEA (SEE) dividends that formed part of net production value in excess of 5%. The measure also includes instructions for completing the form. Italian companies that paid IRAP on qualifying cross-border dividends above the 5% threshold may now file formal refund or compensation claims using the approved model pursuant to Articles 6 and 7 of Legislative Decree 446/1997.