We hereby inform you that Article 1, paragraphs 44 and 45 of Law No. 199 of 30 December 2025 (“2026 Budget Law”) has provided for the reopening of the terms for the step-up-in-value regime for reserves under the tax-suspension regime.
The provision follows the structure of Article 14 of Legislative Decree No. 192/2024 (referred to in our Circular 18/2024 of 17/12/2024), which recognized the possibility of release revaluation surpluses, reserves and funds still existing in the financial statements as of 31 December 2023, by paying a substitute tax at a rate of 10% in lieu of income taxes and IRAP.
