the automatic or early discharge of the sums entrusted to the Revenue Collection Agency (Article 3).
2 The current scenario
Over 1,200 billion in outstanding debts
There are too many defaulting taxpayers who are increasingly “swelling” the so-called warehouse of debts on the roll. A warehouse that – as reported by the director of the Revenue Agency, Ernesto Maria Ruffini, on the occasion of Telefisco 2024 – based on the latest data as of December 31, 2023, counts “over 1,206.6 billion euros, which concern approximately 163 million tax bills and assessment notices and 22.4 million taxpayers”. This enormous warehouse concerns 3.5 million companies, foundations and entities and 18.9 million individuals, of which 3 million are owners of economic activities. According to the Tax Office, once the irrecoverable sums for debts relating to deceased persons, penniless persons or closed companies have been removed, 101.7 billion remain to be collected (approximately 8%); among the debtors, moreover, there are subjects who cannot be seized due to limits related to the first home or capital goods.
3 Clean up the warehouse
Automatic or early discharge
The sums entrusted to the Revenue Collection Agency (Ader) from 1 January 2025, not collected by 31 December of the fifth year following the year of entrustment, will be automatically discharged as established by the decree of the Ministry of Economy and Finance (Article 3). The establishment of a commission is foreseen, to cancel all or part of the so-called warehouse of debts on the roll; to achieve the discharge, the commission will propose the solutions to be adopted, with legislative measures, by: 31 December 2025 for the charges entrusted from 2000 to 2010; 31 December 2027 for the charges entrusted from 2011 to 2017; 31 December 2031 for the charges entrusted from 2018 to 2024 (Article 7).
4 Give and take
Credits exceeding 500 euros are offsettable
Article 16 of Legislative Decree 110 amends the decree on collection, Presidential Decree 602/1973. Article 28-ter (“Payment through voluntary compensation with tax credits”) is amended, providing that:
payment by voluntary compensation can only be made for refunds exceeding 500 euros, including interest;