2027 Budget Law: the tax measures under discussion and the (possible) flat-rate tax on shop leases
Work on the next Budget Law is under way, but for now the scope of the tax measures rests on early comments made in interviews and public speeches. None of the proposals is contained in a legislative text: the Draft Budgetary Plan (Documento Programmatico di Bilancio) has yet to be submitted to Parliament. The indications gathered in recent days should therefore be read for what they are: statements of intent, often conditional and hypothetical.
Irpef: the 33% rate up to EUR 60,000
Deputy Minister for the Economy Maurizio Leo, speaking at the “Speciale Telefisco 2026” event organised by “Il Sole 24 Ore”, identified as a priority the extension of the 33% rate to the EUR 50,000–60,000 bracket of total income, currently taxed at 43%. Following the reform that has already set the rate for the EUR 28,000–50,000 bracket at 33%, the portion of income above EUR 50,000 would therefore move from 43% to 33%. This change would result in a maximum saving of one thousand euro per year for each taxpayer.
It should be stressed, in any case, that the Deputy Minister himself made all the measures conditional on finding the necessary resources and on the full agreement of the parties of the governing coalition.
Flat tax for young people
The idea was put forward by Minister Giancarlo Giorgetti who, according to “Il Sole 24 Ore”, launched it and has reiterated it on several occasions, envisaging favourable taxation of salary increases for younger workers, to be designed with the cooperation of employers. At the “Telefisco” event, Deputy Minister Leo took it up in hypothetical terms, referring to a flat tax mechanism on income paid to young people, to be combined with an incentive for businesses. No technical details have emerged so far, such as the rate, the maximum age (35 is a recurring threshold in tax incentives) or the scope of beneficiaries. The approach recalls the one adopted last year with the flat tax on pay rises arising from collective agreement renewals, but for now no further information is available.
Flat-rate regime: from EUR 85,000 to EUR 100,000
On the flat-rate regime (regime forfettario), Minister Giorgetti expressed openness to raising the threshold, currently set at EUR 85,000. According to ANSA, which attended the conference, the Minister nevertheless pointed to the need to overcome the European limit, which he considers unjustified, and therefore to discuss the matter with Brussels.
Flat-rate tax (cedolare secca) on commercial leases
This is the opening that deserves the most attention, as it recalls a concrete precedent.
What the Minister said. At Telefisco he recalled the 2019 measure on the flat-rate tax for commercial properties, adding that he believes it could be adopted again "under certain conditions, within certain limits". “Il Sole 24 Ore” notes that the tax reform enabling law had revived hopes of preferential taxation of commercial properties, but the principle has remained unimplemented. There is talk of limiting the measure to properties of up to 300 square metres.
The 2019 precedent. Art. 1, para. 59, Law 145/2018 had extended, by election, the 21% flat-rate tax to certain commercial lease agreements. It was a temporary measure with clearly defined boundaries:
it applied only to agreements entered into in 2019;
it was limited to shops and workshops in cadastral category C/1, up to 600 square metres, together with appurtenances leased jointly;
it applied only to individual landlords not acting in the course of a business, art or profession, whereas the tenant could also be a business (Circular no. 8/E/2019 and Resolution no. 50/E/2019);
it was excluded if, on 15 October 2018, an unexpired agreement already existed between the same parties for the same property and was terminated early. The clause was intended to prevent existing agreements from being terminated and re-executed solely to obtain the flat-rate tax.
The issues that emerged. In practice, the measure created two main uncertainties, both linked to the fact that it applied only to agreements entered into in 2019. The first is when an agreement can truly be considered new. The Italian Revenue Agency looked at the substance: in ruling no. 364/2019 it denied the flat-rate tax for a shop leased since 2014, in which a new tenant had taken over as a result of the lease of a going concern. A takeover is not a new lease, nor is a change in the rent. The second concerns subsequent years: in ruling no. 184/2020 the Agency clarified that the time limit refers to the year in which the agreement is entered into, not the year in which the election is made. Those who did not opt immediately may do so for subsequent years.
What a new version should clarify. If the measure is reintroduced, the text will need to clarify at least whether it will be temporary or permanent, whether it will remain limited to shops (C/1) or be extended to other business properties such as offices and professional studios, what the floor-area limit will be and how existing agreements will be treated.
Conclusion
The indications are politically significant, but they reflect different degrees of commitment. The Irpef cut is the most definite; the flat tax for young people and the flat-rate tax on shops are framed in hypothetical terms, while the flat-rate regime depends on discussions at European level. The decisive moment will be the Draft Budgetary Plan, followed by the text of the Budget Bill. Until then, it is premature to plan transactions or advise clients on the basis of these hypotheses, other than to bear them in mind as a hypothetical scenario.
