Response No. 189/2026 – Subject: Employee welfare – Tax treatment of fringe benefits granted to employees ordinarily assigned to Sunday service – Article 51, paragraph 3, of the Italian Income Tax Code (TUIR)
With Response No. 189/2026, the Italian Revenue Agency clarified that fuel vouchers and shopping vouchers granted under a welfare plan to employees who ordinarily work on Sundays may qualify as fringe benefits governed by Article 51, paragraphs 3 and 3-bis, of the Italian Income Tax Code (TUIR).
On that basis, the benefits do not count towards employment income, for tax and social security purposes, within the overall thresholds set by current legislation.
Table of contents
- The case
- The tax regime for fringe benefits
- Fuel vouchers and shopping vouchers as fringe benefits
- The plan for employees assigned to Sunday service
- The clarification of the Italian Revenue Agency
The case
The case concerns a company entrusted with essential public services organised seven days a week, which intends to introduce, for the 2026-2027 two-year period, a welfare plan for employees called upon to work ordinarily on Sundays.
The plan provides for the monthly provision of fuel vouchers and multi-purpose shopping vouchers, the value of which varies according to how often the employee’s organisational unit requires Sunday service.
The company explains that the benefit is intended to support employees most affected by work arrangements that are potentially more burdensome in terms of work-life balance, and that it is not a bonus linked to individual performance or productivity. A specific allowance for Sunday work is also already provided for under the applicable collective agreement and company-level bargaining.
The company therefore asks whether the vouchers may qualify as fringe benefits and benefit from the related tax exemption.
The tax regime for fringe benefits
Article 51, paragraph 1, of the Italian Income Tax Code (TUIR) sets out the general principle that employment income is all-inclusive: all sums and values received by the employee in connection with the employment relationship count towards income.
However, paragraph 3 introduces a specific threshold within which the value of goods transferred and services provided to the employee does not count towards income.
For the 2025, 2026 and 2027 tax years, Article 1, paragraph 390, of Law No. 207/2024 temporarily raised this threshold to:
- EUR 1,000 for employees in general;
- EUR 2,000 for employees with dependent children for tax purposes.
The limit must be verified by considering cumulatively the value of fringe benefits and any sums paid or reimbursed by the employer for household utilities, rent for the main residence or interest on the mortgage for the main residence, in the cases provided for by law. To apply the higher EUR 2,000 threshold, the employee must declare to the employer that they are entitled to it, indicating the tax code of the dependent children.
If the applicable threshold is exceeded, the entire value of the fringe benefits counts towards income, not just the portion exceeding the limit.
From 1 January 2027 the rules will be incorporated into Article 53, paragraphs 4 and 5, of the new Consolidated Income Tax Act (Legislative Decree No. 117/2026).
Fuel vouchers and shopping vouchers as fringe benefits
Article 51, paragraph 3-bis, of the Italian Income Tax Code (TUIR) allows the employer to provide goods and services also through entitlement documents, in paper or electronic form, to which a nominal value is assigned.
As clarified by the Italian Revenue Agency in Circular No. 28/E of 15 June 2016, in-kind benefits provided through vouchers representing goods or services, including fuel vouchers, also fall within the scope of fringe benefits.
In the case of multi-purpose vouchers, the employee may use the assigned value for a variety of goods or services, in compliance with the conditions set by the rules on entitlement documents. Entitlement documents must meet the conditions laid down in Article 6 of the Ministerial Decree of 25 March 2016, including being personal, non-transferable and non-convertible into cash.
For multi-purpose vouchers representing several goods or services, the decree and Circular No. 28/E/2016 refer to a limit of EUR 258.23 per single voucher, separate from the annual tax-exemption thresholds raised to EUR 1,000 or EUR 2,000. Response No. 189/2026 does not expressly clarify how these limits are to be coordinated in practice.
The plan for employees assigned to Sunday service
A central aspect of the Response is that the benefits are granted only to employees who ordinarily work on Sundays and that their value varies according to the frequency of Sunday service required by the organisational unit.
As represented by the company, the plan is not intended to remunerate a specific work performance, nor is it a performance incentive, a productivity bonus or a results-based bonus.
Its purpose is instead to support a particular group of employees by reason of the structural organisation of work and its possible effects on work-life balance. In this specific case, moreover, Sunday work is already remunerated through a specific allowance provided for by collective and company-level bargaining.
In light of the characteristics declared by the company, which the Italian Revenue Agency takes as represented, the vouchers may qualify as fringe benefits without being regarded as additional consideration for Sunday work. This conclusion presupposes that the circumstances described correspond to the actual implementation of the plan, without prejudice to the audit powers of the tax authorities.
The clarification of the Italian Revenue Agency
The Italian Revenue Agency concludes that the fuel vouchers and multi-purpose shopping vouchers provided for by the plan may qualify as fringe benefits governed by Article 51, paragraphs 3 and 3-bis, of the Italian Income Tax Code (TUIR). Consequently, such benefits do not count towards employment income for tax and social security purposes, provided that the overall limits set by current legislation for the relevant tax year are complied with.
The clarification also confirms that the fact that the plan is aimed at employees characterised by a particular way of organising their work does not, in itself, preclude the application of the fringe benefit regime.