Last Updated on September 24, 2026
Article 1 of Legislative Decree 148 of 07/08/2026 (the so-called “Omnibus” Decree), published in Official Gazette 185 of 11 August 2026, reinstates the list of potential beneficiaries of corporate welfare cash and non-cash benefits, perks, and programmes as detailed in Article 12 of the Consolidated Income Tax Act (TUIR) prior to the changes made initially by the 2025 Budget Law and subsequently by Legislative Decree 192 of 18 December 2025, which significantly limited the number of possible beneficiaries of corporate welfare, creating several critical issues for all market operators, including so-called welfare providers.
Article 2 of the Decree amends provisions regarding taxation of fringe benefit cars and related optional extras.
One of the aims of this Decree is to do away with the heavy taxes incurred by calculation of the normal value, rendered necessary by the Revenue Agency interpretations of the previous regulatory changes introduced in 2025, and to regulate evaluation of the particular car model and optional extras.
The new provisions of the Decree:
as from the 2026 tax period;
state that:
- the value of the fringe benefit must always be calculated on the basis of a conventional annual mileage of 15 thousand kilometres at the per-kilometre cost outlined in the ACI tables, multiplied by 50%, 20%, or 10% depending on the type of engine (petrol/diesel, plug-in, or full electric), net of any sums deducted from the employee in relation to concession of the vehicle, including those linked to the particular model and optional extras.
- This reduction of the taxable value of the fringe benefit based on the cost of the particular car model and optional extras is an innovation that definitively exceeds the recent contrary interpretations by the Revenue Agency on this point.
- the value of the fringe benefit determined according to the above criterion must be increased by 50% after 31 December of the fifth year after initial registration of the vehicle;
- should the car have accessories (a particular car model or optional extras) not included in the ACI tables and not directly purchased by the worker, the value of the fringe benefit determined according to the above criterion must be increased by 5%.
In addition, the Decree, for:
- vehicles granted for mixed use from 1 July 2020 to 31 December 2024; and
- vehicles ordered by employers by 31 December 2024 and granted for mixed use in the year 2025;
stipulates that:
- the regulations in force as of 31 December 2024 until 31 December of the fifth year following the first registration must be applied and backdated;
- from 1 January of the sixth year following the year of first registration, the value of the fringe benefit calculated in accordance with the provisions of the preceding points must be increased by 50%.
The regulatory framework applicable for the identification of corporate welfare beneficiaries and for the taxation of fringe benefit cars therefore appears to be particularly complex.
