OMNIBUS DECREE: NEW DEVELOPMENTS REGARDING THE TAX VALUATION OF BONDS

Newsletter

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In this circular, we wish to inform you of a new provision introduced by the ‘Omnibus’ Decree (Legislative Decree No. 148 of 7 August 2026, published in the Official Gazette No. 185 of 11 August 2026, Supplement No. 30) concerning business income, relating to the tax valuation of bonds recorded in the balance sheet by entities that adopt national accounting standards.

Specifically, depending on the classification of the securities in the balance sheet, the regulations currently in force can be summarised as follows.

Article 94(4) of the TUIR, as amended by the ‘Omnibus’ Decree, provides that, for bonds and other serial or mass securities (such as, for example, units in collective investment schemes), recorded under current assets, the valuation applied at the end of the financial year in accordance with the correct application of accounting standards shall be recognised. The new rules therefore ensure full alignment between the book value and the tax value of such securities.

Cover of RLVT Circular 22/2026 on tax valuation of bonds: new developments in the Omnibus Decree