The Legislative Decree No. 123 of 1 August 2025, containing the new Consolidated Act of legislative provisions on registration tax and other indirect taxes, was published in the Official Gazette No. 186 on 12 August 2025. The decree was adopted in implementation of the enabling law of 9 August 2023, No. 111.
The measure forms part of a broader process of rationalization and codification of tax legislation, pursuing—consistent with the guiding principles and criteria already applied in previous Consolidated Acts—a precise and systematic review of the current legal framework. In particular, the new Consolidated Act provides for:
- the organic identification of existing rules, organized by homogeneous sectors;
- the formal and substantive coordination of provisions, including those implementing and transposing European Union law;
- the express repeal of incompatible or outdated rules.
The Consolidated Act governs registration tax and other indirect taxes excluding VAT, unifying provisions on mortgage and cadastral taxes, inheritance and gift taxes, stamp duty, stamp duty on securities and financial assets, as well as IVAFE, also applicable to crypto-assets.
Regulatory Rationalization and Continuity of Application
The simplifying value of the new Consolidated Act is clearly evident in the fact that it merges into a single legislative body the provisions previously contained in:
- DPR No. 131/1986 (Consolidated Act on Registration Tax – TUR);
- Legislative Decree No. 346/1990 (Consolidated Act on Inheritances and Donations – TUS);
- Legislative Decree No. 347/1990 (Consolidated Act on Mortgage and Cadastral Taxes – TUIC).
The legislative “compilation” was carried out without altering the wording of existing provisions, except in cases where it was necessary to:
- update the text to reflect subsequent legal amendments;
- introduce coordinating provisions for systematic purposes;
- improve the logical and legal consistency of the overall framework.
The drafting of the Consolidated Act also considers the changes already introduced by Legislative Decree No. 139/2024, which initiated the rationalization of indirect taxes other than VAT, with impact on registration tax and inheritance and gift taxes.
Structure of the Consolidated Act
The new Consolidated Act consists of 205 articles divided into six Parts, supplemented by specific tariff and tabular annexes.
Specifically:
- Part I: registration tax;
- Part II: mortgage and cadastral taxes;
- Part III: inheritance and gift taxes;
- Part IV: stamp duty, special stamp duty on securities and financial assets, as well as IVAFE, applicable to financial products, bank accounts, savings books, and crypto-assets;
- Part V: substitute regimes (funds with contributions of real estate, corporate transformations in the port sector) and the regulation of reliefs and exemptions for registration tax and other indirect taxes;
- Part VI: final provisions, rules of authentic interpretation, list of repealed provisions, and entry into force.
Excluded from the compilation are provisions on tax assessment and penalties, which continue to be regulated autonomously.
Reliefs and Exemptions
A specific section of the Consolidated Act is dedicated to relief and exemption regimes already provided by special laws, limited to taxes included in the Consolidated Act. Reliefs related to autonomous sector-specific provisions or framework laws affecting other tax areas have not been included.
Annexes and Tariffs
The Consolidated Act is accompanied by four annexes:
- Annex 1: registration tax rates, with the list of deeds subject to fixed-term registration, use, or exemption; includes provisions from special laws, such as the “first home” tax credit (Art. 7, Law No. 448/1998);
- Annex 2: deeds subject to mortgage and cadastral taxes;
- Annex 3: deeds subject to stamp duty from inception, by use, or exempt;
- Annex 4: table of coefficients for registration tax and inheritance and gift taxes.
Entry into Force
The decree provides for the entry into force of the Consolidated Act from 1 January 2026; however, the “Milleproroghe” Decree (DL No. 200/2025) postponed to 1 January 2027 the effectiveness of the main Consolidated Tax Acts already adopted, including the one concerning registration tax.
