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Law No. 199/2025 introduced a new facilitated definition procedure for loads entrusted to collection agents during the period between January 1, 2000 and December 31, 2023, commonly referred to as “Rottamazione quinquies.”
The institute allows taxpayers to regularize their debt position with a significant reduction in accessories, providing for the waiver of administrative penalties and interest entered on the tax rolls, including interest on arrears. Instead, the principal and costs of notification and any enforcement procedure remain due in full. Debts arising from automatic settlement and formal control of tax returns, INPS social security contributions declared but not paid, and penalties for traffic violations imposed by state administrations fall within the scope of application.
Adherence to the procedure must take place, under penalty of forfeiture, by April 30, 2026, by submitting a special application exclusively in telematic mode, through the portal of the Agenzia delle Entrate-Riscossione. With the application, the taxpayer identifies the loads subject to definition, opts for lump-sum payment or installment payments and undertakes to waive any pending judgments concerning the same roles.
Submission of the petition produces relevant legal effects. In particular, the statute of limitations and forfeiture periods relating to definable loads are suspended; new precautionary or enforcement actions may not be initiated and those in progress remain suspended, unless a positive outcome of the enchantment has already occurred. However, administrative detentions and mortgages already registered on the date of the application remain effective.
Communication from the Collection Agent
By June 30, 2026, the collection agent shall notify the debtor of the total amount of the amounts due and the details of the payment plan. Payment may be made in a lump sum by July 31, 2026 or by installment up to a maximum of 54 bimonthly installments, with extension of the plan until 2035. Interest at the rate of 3 percent per year accrues on the deferred amounts as of August 1, 2026. Offsetting via F24 form is not allowed.
Forfeiture of scrapping
Failure or insufficient payment of two installments, even if not consecutive, or of the last installment results in automatic loss of the benefits of the facilitated definition. In such a case, enforcement recovery activities resume and the previously suspended statute of limitations and limitation periods resume.
The measure is, therefore, a relevant opportunity for regularization, but it requires a careful assessment of the financial sustainability of the chosen plan, in light of the strict forfeiture regime provided by the rule.
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