The tax authority as a tutor for businesses is revving up the engine. And a further boost is coming after the wide-ranging circular (the ) signed on Thursday, August 6 by the Revenue Director Vincenzo Carbone and the amendments to the Omnibus decree (finally approved on Tuesday by the Council of Ministers) under the impetus of the Deputy Minister of Economy Maurizio Leo. The latest news is that the counter now shows 224 companies admitted to the cooperative compliance regime (the collaborative compliance).
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Growing numbers
The list of admitted companies is therefore growing compared to the last update which at the end of 2025 showed 221 memberships. Important progressive numbers because for the moment these are very large companies. Just think that at the end of last year the monitored taxable amount was estimated around 49 billion euros. Figures that explain why the tax administration is investing in this disclosure regime by companies, which are required to certify their tax risk management system, and then once entry has occurred, accompaniment by the Revenue Agency.
The potential of 11,000 companies
Currently, the main entry door to the regime is represented by the threshold of 500 million euros in turnover or revenue (if the requirements are met, entry is also possible through other “side” doors such as, for example, the new investments ruling). But from 2028 the threshold will be lowered to 100 million euros, as provided by the timetable outlined by the implementation of the tax reform. An expansion that could embrace another 11,000 companies. Without forgetting, however, the most critical challenge: the optional entry by SMEs, which are below the size threshold. A challenge that is first and foremost cultural: overcoming even the obstacle of initial costs to equip and certify the tax control framework (TCF) can have future advantages not only in relations with the tax authorities but also, among others, with stakeholders and the financial and banking world for access to credit.
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Certainty about the future but also about the past
A lever to further convince to join has come from the Omnibus decree. In addition to extending until December 31 the period for the certification of the TCF of companies that applied for membership in 2024 and 2025, the provision intervenes on tax risks prior to entry. With the possibility of deferring taxes due up to 20 quarterly installments and without penalties from voluntary disclosure. A chance that allows greater peace of mind especially on those more complex issues to manage that could be subject to a different interpretation between the tax administration and the taxpayer. This is the case, for example, of divergences regarding the application of international accounting principles.
The enrichment
The action scheme is actually a sort of enrichment of what is already provided now for companies with the size requirements to enter cooperative compliance. Therefore, communications of prior tax risks must be “unconditionally made within one hundred and twenty days from the notification of the admission provision to the regime” but above all must be made “before the taxpayer has had formal knowledge of accesses, inspections, audits or the start of any administrative assessment activity or criminal investigations on the communicated risks”.
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