Budget Law 2023: introduction of special repentance


published on 15 March 2023 | reading time approx. 2 minutes

Among the various innovations provided for by Law No. 197/2022 on the settlement of tax matters, the possibility of benefitting from a special type of correction of mistakes has been introduced, through which tax violations can be remedied by paying penalties reduced to 1/18th of the minimum. 

Budget Law 2023 has introduced various methods for the settlement of tax disputes. These options do not consist of conceptually innovative institutes, but they strengthen pre-existing legal institutes, such as the “accertamento con adesione” (tax settlement proposal) or the conciliazione giudiziale” (court settlement).

These include the institution of “ravvedimento speciale”, which is a special possibility of removal of violations on declarations committed until 31 December 2021 on taxes administered by the Revenue Agency through the payment of reduced penalties, in addition to the tax and the interest due (L. 197/2022, art. 1, par. 174 et seq.).

It differs from the ordinary “ravvedimento operoso” pursuant to Article 13 of Legislative Decree 472/1997 in that the penalties are reduced to 1/18th of the minimum and that payment can be made in instalments. 

In fact, the payment can be made in eight quarterly instalments of equal amount, to which interest at the rate of 2 per cent per annum is to be added. 

Both the payment of the amount due, or of its first instalment, and the removal of the infringement must take place by the final deadline of 31 March 2023.

Regularisation is permitted if the breaches have not already been contested, at the date of payment of the amount due or of the first instalment, by an act of liquidation, assessment or recovery, dispute and imposition of sanctions, including the communications referred to in Article 36-ter of Presidential Decree No. 600/1973. 

Excluded from the possibility of benefiting from the special amnesty are violations concerning the omitted or incorrect filling in of the RW section of the tax retuns, violations on payments, omitted declarations and formal violations. Reparations already carried out as of 01 January 2023 pursuant to Article 13 of Legislative Decree 472/1997 remain valid and there will be no refund of the amount paid.



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Eleonora Mangia


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Birgit Rauschendorfer


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