The Agreement betweet Tax payers and Tax italian Administration (CPB) is an option that allows taxpayers to pre-establish the taxable income for two years, providing greater fiscal certainty. However, we know well that the income of a business or a professional can vary over time, which may lead to a discrepancy between the actual income and the agreed-upon amount. What happens in these cases? Let's explore the possible consequences together.

If the actual income is higher

If the actual income produced over the two years is higher than the agreed-upon amount, this variation does not cause any issues. The taxpayer retains the benefits of the agreement and does not have to pay additional taxes on the excess amount. Essentially, this is an advantage because the extra income will not be subject to potential tax audits by the Revenue Agency.

The only decision the taxpayer needs to make concerns social security contributions: they have the option to pay them on the income portion that exceeds the agreed-upon amount, but it is not mandatory to do so.

If the actual income is lower

If the actual income is lower than the agreed-upon amount, the situation changes slightly. In most cases, the agreement remains valid, and the taxpayer will still need to pay taxes based on the agreed income. However, there is an important exception: if the actual income is more than 50% lower than the agreed amount, the CPB could lose its validity. In this case, the Ministry of Economy and Finance may introduce measures to manage extraordinary situations.

Additionally, on the portion of the agreed income that exceeds the actual income, a substitute tax may be applied. For those using the ordinary regime with good ISA scores, this tax ranges from 10% to 15%. For flat-rate taxpayers (forfettari), the tax is 10%, while for startups under the flat-rate regime, it is reduced to 3%.

Practical considerations

The CPB is useful for those seeking fiscal stability and aiming to plan their payments with certainty. However, before opting in, one should ask: Could my income experience significant fluctuations over the next two years? If the answer is yes, it might be better to consider alternatives or adopt a more flexible strategy. On the other hand, if you have a reliable income forecast and want to avoid audits, participating in the CPB can be a smart choice.

DTA