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  • Studio Paci

ISA 2023: the exclusion applies to subjects who started their activities during the course of 2021.

The Ministerial Decree establishing a new form of extraordinary exclusion for the fiscal year 2022 has been published. The Ministerial Decree of April 28, 2023, titled "Approval of amendments to the synthetic indices of fiscal reliability applicable for the tax period 2022," can be accessed at the following link.

The Decree is currently in the process of being published in the Official Gazette.

In accordance with Article 8 of the decree, the following is outlined: "For the tax period ending on December 31, 2022, the synthetic indices of fiscal reliability, in force for the same tax period, do not apply to subjects who have opened their VAT number starting from January 1, 2021"; "Taxpayers excluded from the application of the indices based on the provisions of paragraph 1, are still required to communicate economic, accounting, and structural data."

The decision is the result of evaluations carried out by the Expert Commission, appointed by the Ministry of Economy and Finance (MEF) under Article 9-bis, paragraph 8 of Legislative Decree 50/2017, for the fiscal year 2022.

This commission proposed this form of extraordinary exclusion in response to the persistent uncertainty caused by the spread of Covid-19 and geopolitical tensions, in a macroeconomic context aggravated by inflationary pressures and rising interest rates.

The instructions for the ISA 2023 model have been promptly updated to include the new exclusion clause "q", specifically aimed at subjects who started their VAT number from January 1, 2021.

Conversely, the instructions for the Income models have not yet been modified, hence the corresponding exclusion code is not yet known.

Taxpayers who intend to benefit from this form of extraordinary exclusion are required to prepare and submit the ISA 2023 model attached to the Income model. However, in completing the form, it is not mandatory to acquire and integrate the precalculated variables provided by the Agency.

Furthermore, it is not necessary to calculate the reliability score, as this score cannot be improved by declaring additional revenues.

The exclusion cause in question concerns taxpayers who started their activity from January 1, 2021. Therefore, for the Income statement for the fiscal year 2022, only those who started the activity in 2021 and 2022 can take advantage of it.


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