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  • Studio Paci

📊 Preliminary Tax Notices 2025: New Timelines and Tax Procedures

🕰️ Extension of Payment Terms for Preliminary Tax Notices

Starting in 2025, the Italian tax landscape will undergo a significant transformation with the extension of the response time for preliminary tax notices.

In the final version of the corrective decree, approved yesterday by the Council of Ministers, a significant change has been introduced: the extension of the response time for preliminary tax notices from 30 to 60 days.

This modification represents a substantial shift in the management of tax obligations, offering taxpayers a longer period to organize their tax position.

The extension does not merely double the time available but introduces a new philosophy in the relationship between the tax authorities and the taxpayer. This greater temporal flexibility allows for a more accurate evaluation of the requests from the Revenue Agency, enabling taxpayers to:

  1. Conduct a thorough analysis of their tax situation.

  2. Collect the necessary documentation more completely.

  3. Consult with industry experts for professional evaluation.

  4. Plan potential payments more sustainably.

Additionally, this change could lead to a reduction in tax disputes, encouraging a faster and more collaborative resolution of any discrepancies found.

Aspect

Old Provision

New Provision (2025)

Preliminary tax notice terms

30 days

60 days

Potential disputes

High

Reduced

Time for tax analysis

Limited

Extended

Payment planning

Restricted

Expanded

📅 New Filing Deadlines: Advancement and Reorganization

A significant advancement of the deadlines for filing tax returns is also being introduced.

From 2025, the final deadline will shift from November 30 to September 30, with an important novelty: the possibility to start submitting returns from April 1 of each year.

This reorganization of the tax calendar could have several implications:

  • Expanded timeframe: Six months for the preparation and submission of returns.

  • Workload distribution: Possibility to manage obligations more evenly.

  • Earlier audits: The Revenue Agency will be able to start verification activities sooner.

  • Impact on tax planning: Need to adjust financial management strategies.


For corporate taxpayers (IRES), the new deadline will be set to the last day of the ninth month following the end of the tax period, aligning the timing with that of individuals and simplifying the tax deadlines landscape.

Aspect

Old Provision

New Provision (2025)

Filing deadlines

November 30

September 30

Start of filing

Not specified

April 1

Filing period

About 7 months

6 months (more defined)

Deadline alignment

Differentiated

Unified for multiple entities

💼 Flexibility in Collection Procedures: A New Approach

With the new provisions, the Revenue Agency will have the ability to implement more flexible collection procedures.

This change should translate into:

  • More effective management of communications with taxpayers.

  • Greater customization of payment plans.

  • Potential reduction in the bureaucratic burden for both parties.

The introduced flexibility aims to facilitate the regularization of tax positions, encouraging voluntary compliance and reducing the recourse to coercive measures.

This more collaborative approach could lead to:

  1. A decrease in tax disputes.

  2. An improvement in the perception of the tax system by taxpayers.

  3. Greater efficiency in the collection of due taxes.


Furthermore, the suspension of sending preliminary tax notices and other communications in August and December is expected, except in cases of urgency and non-postponement.

Aspect

Old Approach

New Approach (2025)

Collection procedures

Rigid

Flexible

Communications

Standardized

Personalized

Suspension periods

Not provided

August and December

General approach

Coercive

Collaborative

📈 Impact on Tax and Filing Deadlines

The changes introduced by legislative decree 1/2024 not only affect preliminary tax notices but also impact the deadlines for filing tax returns.

Starting in 2025, the deadline for submitting tax returns will be moved up from November 30 to September 30. For corporate taxpayers (IRES), the deadline will be set to the last day of the ninth month following the end of the tax period.

This advancement in filing deadlines is accompanied by another important novelty: from 2025, it will be possible to start submitting returns from April 1 of each year.

This change offers a broader timeframe for the preparation and submission of returns, allowing for a more balanced distribution of the workload throughout the fiscal year. The advancement of deadlines, combined with the extension of the submission period, aims to improve the efficiency of the tax system, enabling the tax administration to start control and assessment activities more promptly.

At the same time, it offers taxpayers greater flexibility in managing their tax obligations.

Aspect

Old Provision

New Provision (2025)

Filing deadlines

November 30

September 30

Start of filing

/

April 1

Filing period

About 7 months

6 months (more defined)

Deadline alignment

Differentiated

Unified for multiple entities

💳 Changes to the Collection and Installment Payment System

The decree also introduces significant changes to the collection system, with particular attention to the management of uncollected roles and the installment payment possibilities of tax debts.

Starting in 2025, an automatic discharge system will be introduced for uncollected roles after 5 years. This measure aims to streamline administrative procedures and focus collection efforts on more recent and potentially more collectible debts.

Regarding installment payments, the maximum number of installments for ordinary installment payments of tax debts will gradually increase from the current 72 to 120. Additionally, in case of a worsening of the debtor's economic situation, it will be possible to obtain a one-time extension for an equivalent period.

These changes offer greater flexibility to taxpayers in financial difficulty, allowing for more sustainable management of tax debts in the long term.

The extension of installment payment possibilities, combined with the introduction of automatic discharge, seems to represent a more balanced approach to debt management, taking into account both the State's revenue needs and the economic difficulties that taxpayers may encounter.

Aspect

Old Provision

New Provision (2025)

Role discharge

Non-automatic

Automatic after 5 years

Installment payment of tax debts

Max 72 installments

Max 120 installments

Installment payment extension

Not provided

Possible one-time

Approach to collection

Rigid

Flexible and sustainable


 

FAQ


📅 How do the terms for responding to preliminary tax notices change with the 2025 tax reform?

The 2025 tax reform introduces an important change: the extension of the response time for preliminary tax notices from 30 to 60 days.

This modification offers taxpayers a longer period to organize their tax position, allowing for a thorough analysis of the tax situation and more sustainable payment planning. The goal is to improve the tax authority-taxpayer relationship, potentially reducing tax disputes and promoting a more collaborative resolution of any discrepancies.


🗓️ What are the new deadlines for filing tax returns starting in 2025?

With the advancement of filing deadlines introduced by legislative decree 1/2024, from 2025, the final deadline for filing tax returns will move from November 30 to September 30.

A significant novelty is the possibility of starting to submit returns from April 1 of each year.

For corporate taxpayers (IRES), the new deadline will be set to the last day of the ninth month following the end of the tax period, aligning the timing and simplifying the tax deadlines landscape.


💼 How does the 2025 reform introduce greater flexibility in collection procedures?

The reform provides for more flexible collection procedures by the Revenue Agency. This new approach translates into more effective management of communications with taxpayers and greater customization of payment plans.

The flexibility aims to facilitate the regularization of tax positions, encouraging voluntary compliance and reducing the recourse to coercive measures.

Furthermore, the suspension of sending preliminary tax notices in August and December is expected, except in urgent cases, to reduce the stress of obligations during critical periods.


💳 What changes to the installment payment system of tax debts does the 2025 reform introduce?

The 2025 reform brings significant changes to the collection and installment payment system of tax debts. The maximum number of installments for ordinary installment payments of tax debts will gradually increase from the current 72 to 120.

In case of a worsening of the debtor's economic situation, it will be possible to obtain a one-time extension for an equivalent period. Additionally, an automatic discharge system for uncollected roles after 5 years will be introduced, aiming to streamline administrative procedures and focus collection efforts on more recent and potentially more collectible debts.

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