Decree-Law No. 38 published in the Official Gazette No. 72 of 27 March 2026 introduces an articulated set of urgent tax measures. In the area of indirect taxation, the rules on the starting date of the VAT regime of permutative transactions are redefined: in the area of direct taxation, the most significant measures concern the reinstatement of the pre-Budget Act 2026 regime on dividends and participation exemption - with the repeal of the additional requirements introduced by Law 199/2025 and the return to full PEX and partial taxation of dividends - as well as the badwill for IAS/IFRS entities adopter. In addition, an aspect of the starting date of the favourable regime for the return of impatriates is clarified.

On the investment incentives front, the decree extends hyper-depreciation to capital goods of non-EU/EEA origin, eliminating a geographical requirement that limited its application. With reference to the Transition 5.0 tax credit, a benefit equal to 35% of the credit applied for is granted to companies whose applications are submitted after 6 November 2025: a measure that raises, however, significant critical profiles in terms of retroactivity and equal treatment, but which will be subject, according to what the Government anticipates, to corrective action in the interest of companies.

The decree also intervenes on further aspects: the extension of the new withholding tax on commissions to 1 May 2026, the exemption from withholding tax on interest paid to depositors' guarantee schemes until 2028, a threshold exemption from withholding tax for amateur athletes' bonuses, changes to the regulation of compulsory collection, and an increase in stamp duty on account statements in the name of persons other than natural persons.

Finally, Chapter II brings together heterogeneous measures on opera and symphony foundations, supplementary pensions for clergy, financial education, the European Disability Charter and the unified contribution for the State Bar.