ITA Tax issued Circular 8/E on unified rules, CPB membership for period 2026/2027.
New circular brings together rules, clarifications, application cases in single document.
Illustrates access, renewal, benefits, exclusion grounds and main changes for 2026.
Follows May 2026 ITA GVT published Decree of May 11 approval of methodology for two-year preventive settlement agreement for 2026-2027 tax periods, see #298000.
Overview
The circular provides a systematic overview of elements governing the biennial composition with creditors, bringing together all principles found in various sources.
Particularly important for institution based on collaboration of ITA Tax and taxpayers, where certainty plays central role, as do substantive rules governing its operation.
The preventive agreement is a tool that shifts the relationship with the tax authorities from a predominantly supervisory dimension to one of preventive cooperation.
The mechanism is 2-stage: ITA Tax, based on declared data, ISA results, information in public databases, sectoral economic projections, formulates a proposal for income and net production value for the following two years.
The taxpayer can decide to accept it and commit to declaring those amounts regardless of actual results achieved in the two-year period.
Also, allows taxpayers, professionals and offices to have a comprehensive and coordinated overview of the guidelines developed by ITA Tax.
Key Aspects
For 2026-2027 two-year period, choice must be formalized by Nov. 2 (as Oct. 31 falls on Saturday), along with tax return, or alternatively, by submitting CPB form along with just 2026 Income Tax return cover page.
Extra benefits for those renewing membership are, in addition to standard benefits, exemption from compliance visa for up to €100,000 per year for VAT and up to €70,000 for direct taxes and IRAP.
Renewal also includes exemption from compliance visa or guarantee for VAT refunds up to €100,000, while the deadline for assessment activities is extended by two years.
Another advantage is option to pay balance and advance tax payments in installments without interest for tax periods covered by the agreement.
The document replaces previous circulars on topic and systematically addresses CPB regulations, also in light of 2026 regulatory changes and practice-based interventions.
The appendix has clarifications provided in response to questions and FAQs posed by the trade press or by organizations representing economic operator categories.
