Skip to content INPS recently published circular no. 49 of 2024, which illustrates the procedures for applying the conventional wages to be considered for calculating the contributions of Italian workers operating abroad. In addition to providing the conventional wages for 2024, the circular contains detailed instructions for contribution regularization.
It is worth noting that the conventional wages for the year 2024 were defined by the decree of the Ministry of Labor and Social Policies on March 6, 2024, published in the Official Gazette on March 19, 2024, no. 66 (already addressed in our update on the 2024 conventional wages for employees working abroad).
Scope of application
Conventional wages play a fundamental role in calculating the social security contributions of Italian workers operating abroad, for whom the decree-law of July 31, 1987, no. 317, converted, with amendments, by Law no. 398 of October 3, 1987, applies, i.e., workers operating abroad in non-EU countries not bound to Italy by social security agreements.
These provisions apply not only to Italian citizens but also to workers from other EU member states and to non-EU workers with regular residence permits and employment contracts in Italy, but sent abroad by their employer. Conventional wages also apply to workers operating in countries with partial agreements, limited to insurances not covered by social security agreements.
However, the territorial scope of application of the legislation under review excludes EU Member States, Switzerland, the United Kingdom, and countries adhering to the EEA Agreement.
Calculation of conventional wages
The calculation of conventional wages is based on a comparative evaluation with the national remuneration provided for in the reference collective agreement, excluding the foreign allowance. This value is then divided by twelve and compared with sector tables to determine the wage bracket for contribution purposes.
The conventionally determined values can be proportionately redistributed on a daily basis only in the event of hiring, termination of employment, or transfer during the month. In these circumstances, the monthly taxable income identified based on the tables must be divided by 26 days and multiplied by the number of days, excluding Sundays, included in the fraction of the month concerned.
Special cases and variations
The circular provides details on how to manage possible variations during the year, such as:
- qualification changes during the month,
- variations in individual economic treatment from collective agreement during the month,
- accrual of variable compensation during the year.
In the first two cases, the conventional wage corresponding to the intervening change must be considered, with the same effectiveness as the new qualification or the variation in individual economic treatment.
In the third case, it is necessary to recalculate the applicable wage amount, considering the new overall remuneration and, if necessary, make a settlement for previous periods.
Contribution Regularization
Contribution regularizations must be completed by the 16th day of the third month following the publication of the circular.
Therefore, employers who, for the months of January, February, and March 2024, have operated differently from the instructions provided with the aforementioned circular, must proceed with regularization by June 16, 2024, to avoid additional charges. It is essential to carefully follow the procedures indicated for the completion of the Uniemens report in order to correct any differences.
Conclusions
Circular no. 49 of 2024 provides clear guidelines for calculating conventional wages and establishes procedures for contribution regularization, ensuring the correct application of social security regulations for the current year. These provisions are essential for safeguarding the social security rights of Italian workers abroad and demonstrate INPS’s commitment to providing support and clarity in international labor matters.