Skip to content The measure supplements and, to some extent, overlaps with previous versions of the scheme, most recently the Rottamazione quater.
Scope of the definition
The Rottamazione quinquies allows for the tax settlement of debts assigned to the Italian Revenue Collection Agency (Agenzia delle Entrate-Riscossione) within the time period specified by the law, through the payment of amounts due solely as principal.
In line with previous tax settlement measures, the following amounts are written off:
- administrative and tax penalties;
- late payment interest pursuant to Article 30 of Presidential Decree No. 602/1973;
- collection fees (aggio).
The following amounts remain payable:
- costs related to any enforcement proceedings already initiated;
- costs for the service of payment notices.
The provision also identifies a number of excluded debts, including, according to the legislator’s approach, those falling outside the scope of ordinary tax collection or those expressly excluded from the tax settlement scheme.
The measure forms part of the broader framework of facilitated settlement instruments for debts enrolled on tax rolls, pursuing the dual objective of increasing tax revenue and reducing the stock of uncollected receivables.
Eligible taxpayers
The Rottamazione quinquies is available to individual taxpayers as well as legal entities, including businesses and professionals, holding debts that fall within the objective scope of the measure.
The Budget Bill governs the coordination with previous tax settlement schemes, providing for specific limitations or conditions for taxpayers who have already opted for earlier “rottamazioni”, in order to avoid duplicate benefits on the same debts.
Application procedure
The settlement procedure requires the submission of a specific application to the Italian Revenue Collection Agency, exclusively through electronic means and within the deadline established by law.
Upon submission of the application:
- enforcement and precautionary measures relating to the debts included in the settlement are suspended;
- no new enforcement actions may be initiated until a potential forfeiture of the benefit occurs.
The Italian Revenue Collection Agency then notifies the taxpayer of the total amount due, as well as the selected payment schedule.
Payment terms
Under the 2026 Budget Bill, payment of the amounts due may be made:
- in a single lump sum, by the deadline indicated in the communication from the collection authority; or
- by instalments, under a long-term repayment plan of up to 54 bimonthly instalments over a maximum period of 9 years, with the application of instalment interest at the rate established by law.
The instalment option represents one of the key features of the Rottamazione quinquies, as it allows for a particularly extended payment horizon.
Forfeiture of the definition and related risks
The rules governing forfeiture are characterized by a particularly strict approach. Any failure to make payment, including late or insufficient payment of even a single instalment, results in:
- the loss of the benefits of the tax settlement;
- the full reinstatement of the outstanding debt, including penalties and interest, net of amounts already paid.
No grace period is provided for late payments, confirming the restrictive approach already adopted in previous versions of the scheme.
A particularly significant operational issue concerns the consequences of forfeiture from the Rottamazione quinquies. Article 23 of the 2026 Budget Bill expressly provides that, in the event of the loss of the settlement benefits, the residual outstanding debt may not be subject to any further instalment plan, either under Article 19 of Presidential Decree No. 602/1973 or pursuant to other general provisions.
As a result, the remaining amounts due must be paid in full in a single lump sum, with the immediate reactivation of ordinary tax collection procedures, including reinstated penalties and interest. This provision reinforces the particularly stringent nature of the measure and requires taxpayers to carry out a careful and prior assessment of the financial sustainability of the chosen payment plan.