Italy Budget Bill would raise bank and insurer tax burden for 2027–28

Temporary IRES increases

The Bill remains proposed legislation. Article 18 would add three percentage points for the two tax periods following the one in progress on 31 December 2026. For calendar-year taxpayers, the parliamentary dossier describes a 30.5% IRES rate for covered financial intermediaries in 2027 and 2028, compared with 27.5% under the incoming consolidated income-tax code. Fund managers, investment firms and electronic-money institutions are excluded from this temporary increase. Insurers would instead face a 27% rate, compared with the ordinary 24%. A EUR 200,000 credit would apply against the incremental charge, limited to that charge.^[2][3]

Entities using fiscal consolidation or tax-transparency regimes would calculate and pay the surcharge on their own taxable income under the Bill’s special rules. The same article would prevent deferred-tax assets generated by the temporary surcharge from being converted into tax credits. It would also raise, from 2026, the life-insurance mathematical-reserve tax-credit ceiling from 1.25% to 1.285%. The historical-method advance payment for the first affected period would be calculated as though the new surcharge already applied.^[2][3]

IRAP deductions and deferred tax

Article 19 would reduce from 90% to 30% the IRAP deduction for specified administrative expenses and operating-asset depreciation of banks, other financial entities and insurers from the tax period following the one in progress on 31 December 2026. A EUR 90,000 credit would be available against the resulting increase. It would also spread specified advertising expenditure over three years and reduce a referenced 2027 interest-expense deduction from 97% to 96%. Article 20 would defer to later years the 2027 deductions for specified credit-loss, first-time IFRS 9 and related deferred-tax components.^[2][3]

Proposal-stage planning

Multinational financial groups should identify Italian entities by statutory category, model the combined 2027–29 cash-tax and deferred-tax effect, and test consolidation, advertising, interest and deferred-tax-asset positions separately. Detailed modelling should remain provisional: the Bill may change during parliamentary review. This focused article covers Articles 18–20 only and does not represent a whole-package review of the 157-article Budget Bill.^[1][2][3]