On 17 June, Decree-Law No. 84/2025, containing urgent provisions on tax matters (hereinafter, the DL), was published in the Official Gazette - General Series No. 138.

The measure, which entered into force on 18 June 2025, is currently before the Finance Commission (VI) of the Chamber of Deputies for its first reading, with a deadline for conversion set for 16 August 2025.

The Decree-Law introduces measures that involve a wide range of taxpayers, including companies, self-employed workers, Third Sector entities and Public Administrations, and most of the measures adopted represent an - expected and significant - filing down of previous provisions, in order to correct critical issues or application limitations, which we have also pointed out.

In light of this premise, we therefore express our appreciation for the intervention made by the Government, which - although not immediately - has shown sensitivity in intercepting the requests coming from the business world, translating them into concrete and targeted interventions. The attention shown to the needs of businesses is an important sign of listening and of the will to build a fairer, more efficient and sustainable tax system.

It is hoped that the dialogue between institutions and economic partners can continue in an ongoing and constructive manner, so as to allow for a timely adjustment of regulatory provisions, to avoid having to make corrections, both formal and substantive, to measures that, in the meantime, create uncertainty for taxpayers.

The attached memorandum provides an analysis of the main measures of interest to companies contained in the DL, accompanied, where appropriate, by supplementary proposals and food for thought.