Italy proposes temporary IRES surcharge increases for financial businesses

The Chamber record identifies C.3174-bis as a government bill at first reading, assigned to the Budget Commission after provisions were split from the original bill on 4 November. The measure is proposed, not enacted, and may change during the parliamentary process.^[1][2]

Temporary three-point additions

Article 18 would amend Part IV, Title I of Legislative Decree 19 June 2026 No. 117 by adding Article 362-bis. It would add three percentage points to the IRES surcharge rate under Article 86(2) for the tax period following the one in progress on 31 December 2026 and the next period. A separate three-point addition would apply to companies and entities carrying on insurance business. Electronic-money institutions are excluded from the first limb, and a €200,000 reduction would apply against each incremental charge, subject to the tax otherwise due.^[3]

Group and advance-tax mechanics

The draft contains entity-level rules for insurers that elected tax consolidation and for participants in tax-transparency arrangements. It would also restrict the treatment of deferred-tax assets arising from the additions. For the first affected period, advance payments would be computed as though the proposed rules applied to the preceding period. Finance teams should therefore model the proposal by entity, taking account of regulatory activity, tax-group elections, deferred-tax accounting and advance-tax calculations rather than applying a single group-wide assumption.^[3]

What remains open

For calendar-year taxpayers, the two periods would ordinarily be 2027 and 2028. The reviewed text establishes no separate return deadline, filing route or new payment date. Multinationals should identify potentially covered Italian entities and monitor amendments and enactment before changing compliance processes. This focused report does not treat the wider Budget Bill as fully reviewed or any proposed rule as final.^[2][3]