The income tax system is preparing for a significant reorganization. Legislative Decree No. 117 of June 19, 2026, introduces the new Consolidated Law on Income Taxes, intended to progressively replace the 1986 TUIR.
The decree entered into force on July 4, 2026, but the new provisions will apply starting January 1, 2027. For businesses, professionals, and tax firms, a transition period is beginning, during which it will be necessary to become familiar with the new regulatory structure and, above all, the new article numbering.
The measure represents one of the interventions planned under the tax reform mandate and primarily serves to reorganize and coordinate existing regulations. It is not, therefore, a reform that introduces new taxes or modifies taxation levels across the board, but rather a systematization of provisions currently distributed between the TUIR and numerous special laws.
The new Consolidated Law consists of 377 articles, organized into four parts and accompanied by nine annexes. The new structure organically gathers provisions relating to IRPEF (personal income tax) and IRES (corporate income tax), special regimes, global minimum tax, and transitional and final provisions.
The main change for those working daily in the tax field concerns the move away from the numbering of the old TUIR. From January 1, 2027, the articles of Presidential Decree No. 917/1986 will be replaced, in most cases, by the corresponding articles of the new Consolidated Law.
Article 376 of the decree provides for numerous repeals, including Articles 1 to 191 of the 1986 TUIR. However, the provisions are transferred into the new structure with updated numbering and a more consistent placement.
The reorganization also affects regulations that were previously contained in measures other than the TUIR. The new Consolidated Law now includes, among others, provisions relating to the flat-rate scheme, the flat-rate tax on rental income, the regime for inbound workers (impatriates), the taxation of financial income, and shell companies.
For businesses and professional firms, the change will be particularly evident in daily operations. Many regulatory references used in contracts, reports, opinions, resolutions, corporate documentation, and management software will need to be updated to reflect the new numbering.
Some provisions retain their well-known numbers, while others change location completely. The regulations for tax deductions for building renovations and energy efficiency upgrades, for example, move from the current Article 16-bis to Article 17 of the new Consolidated Law. Rules regarding employment income, currently contained in Article 51, will be moved to Article 53, while self-employment income will move from Article 54 to Article 56.
The regulation of business income is also being reorganized. The definition currently contained in Article 55 will be transferred to Article 64, while the provisions on determining business income will move from Article 83 to the new Article 92. Revenues, currently governed by Article 85, will be found in Article 94, while capital gains will move from Article 86 to Article 95.
The new numbering will also affect institutions particularly relevant to corporate tax management, such as the participation exemption, which will move from Article 87 to Article 96; the regulation of dividends received by IRES subjects, which will be transferred from Article 89 to Article 98; and interest expense, currently governed by Article 96, which will be found in the new Article 105.
Provisions relating to depreciation and amortization will also be relocated: the current Article 102, concerning the depreciation of tangible assets, will become Article 111. The regulation of multi-year expenses will move from Article 108 to Article 117, while the general rules on business income components, currently contained in Article 109, will be moved to Article 118.
Particular attention must also be paid to special regimes, which are finally gathered in an autonomous part of the new Consolidated Law. The regulation of the flat-rate scheme, currently contained in Article 1, paragraphs 54 to 89, of Law No. 190/2014, will be located in Articles 232 to 243 of the new text.
The reorganization does not, in itself, involve a change in the substantive requirements of the regime. The access threshold remains fixed at 85,000 euros in revenues or fees, while the 20,000 euro limit for employee and ancillary labor costs remains in place.
The same principle applies to the flat-rate tax on rental income, which is transferred into the new Consolidated Law without modifying the current 21% rate for open-market leases as a result of the reorganization alone.
IRPEF rates are also transferred to the new structure without substantive changes caused by the new Consolidated Law. The new Article 11 incorporates the existing regulations, including the reduction from 35% to 33% of the rate for the second bracket, introduced with the tax legislation applicable from 2026.
The predominantly compilatory nature of the decree is therefore an important element: the change mainly concerns the structure and placement of the rules, not their substantive content. For businesses and professionals, however, the operational impact will be far from negligible.
One of the aspects to monitor most closely will be regulatory cross-references. Over the years, TUIR articles have been included in thousands of documents used daily by businesses: contracts, bylaws, regulations, company policies, internal procedures, documentation relating to welfare and fringe benefits, professional opinions, and forms.
The legislator has provided a specific safeguard clause. When a law, regulation, or other measure continues to refer to a repealed provision, the reference must be understood as being made to the corresponding provision of the new Consolidated Law. This provision prevents the new numbering from automatically rendering references in previous legislation ineffective.
However, the safeguard does not eliminate the need to update corporate and professional documentation. A contract or internal procedure that continues to cite an article of the old TUIR may remain substantially valid, but the regulatory reference must be progressively adapted to the new regulation, especially during reviews or renewals.
Particular attention must also be given to management and tax filing software, which must incorporate the new regulatory structure. The change in numbering does not only affect the citation of articles but can also impact databases, explanatory notes, forms, and systems used for managing tax compliance.
The period between the decree's entry into force and the application of the new provisions thus serves an essential function. The months leading up to January 1, 2027, represent the most appropriate time for businesses and professional firms to verify the regulatory references in their documentation and prepare the necessary adjustments.
Furthermore, the new TUIR is part of a broader process of reorganizing tax legislation initiated with the tax reform mandate. The goal is to concentrate a subject that has developed through numerous legislative interventions over decades into organic consolidated laws, which often made reconstructing applicable provisions complex.
From 2027, therefore, references to income tax regulations will change profoundly in form. For businesses, this is not a change to be addressed only from a formal perspective: knowing the new structure and promptly updating regulatory references will prevent errors in corporate documentation and facilitate administrative and tax work.
The new Consolidated Law thus represents an important step toward more organic and coordinated tax legislation. The real test will now be the transition phase, in which businesses, professionals, and sector operators must manage the move from the historic numbering of the TUIR to the new structure that will come into full effect in 2027.