In brief

Italian Law 197 of 29 December 2022 (2023 Budget Law) was published in Ordinary Supplement No. 43 to Italian Official Journal No. 303 of 29 December 2022 and has been in force since 1 January 2023.

The main measures include:

  • extension of the tax credit for the purchase of electricity and gas to the 1st quarter 2023; reintroduction of the time limits for facilitated assignment of assets to shareholders;
  • reopening of the simplified rules for exclusion of an individual entrepreneur’s immovable property;
  • extension for redetermination of the tax cost of land and equity investments, providing that shares, securities and rights traded in regulated markets or multilateral trading facilities can also be revalued;
  • possibility to release profits and profit reserves relating to equity investments in companies resident in low-tax countries;
  • reintroduction of the limits to the deductibility of costs incurred in respect of parties resident in countries considered non-cooperative (black list);
  • amendment of the tax regime for capital gains generated by non-residents in relation to the sale of equity investments in companies owning immovable properties in Italy;
  • reintroduction of the institution of settlement of pending tax disputes.

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