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With the final approval of the law converting DL 19/2025 (the so-called DL Bills), the new rules on the taxation of company cars assigned for mixed use by employees, introduced by the Budget Law 2025.
In particular, the application of the previous fringe benefit calculation rules was confirmed in the text in force on 31 December 2024 (more favourable for non-fully electrically powered cars), in the following hypotheses:
- vehicles granted for mixed use from 1 July 2020 to 31 December 2024 (safeguard clause);
- vehicles ordered by employers before 31 December 2024 and granted for mixed use from 1 January 2025 to 30 June 2025 (transitional rules).
This formulation makes it possible, positively, to maintain the lump-sum determination of the fringe benefit, with the coefficients in force until 31 December 2024, to the allocations in existence at the time of the entry into force of the Budget Law 2025, thus avoiding the complex analytical determination of the normal value of the private use of the company car for companies.
The rule also has the merit of averting a 'literal' application of the 2025 rules, on the basis of the cash criterion, to allocations concluded in the first six months of 2025, but which were started by the companies in 2024, making 'legitimate reliance' on the stability of the previous rules.
We will continue our institutional interlocutions with the financial administration, to request the issuance of practice documents to clarify the scope of the aforementioned provisions.
