The 2027 Budget could reintroduce the dry tax on commercial rents. However, the Government is working on a selective measure, with the aim of supporting consumption, local trade and medium-low incomes without compromising the balance of public finances.
Dry coupon for shops
The hypothesis on the table of the Ministry of Economy foresees a flat tax of 21% on the rents of some commercial properties. The measure should mainly concern:
- neighborhood shops;
- shops;
- premises classified in the land registry in category C/1.
The measure could be reserved for new contracts stipulated starting from 2027. In this way, owners of commercial properties could apply a substitute tax instead of the ordinary Irpef taxation. The coupon would also replace the regional and municipal surcharges, the registration tax and the stamp duty.
What the previous coupon was like and what it will be like
The extension of the flat rate tax to commercial rentals would not be new. A similar regime was introduced by the 2019 Budget Law, but only for contracts stipulated in the same year. The law provided for a rate of 21% for C/1 shops and workshops with a surface area of up to 600 square metres. The cost to the Treasury was estimated at between 160 and 163 million euros per year.
For the new version, the Government seems oriented towards narrowing the scope of the relief. The threshold could drop to 250-300 square meters, a size believed to be more consistent with most neighborhood stores.
According to estimates reported in the debate on the measure, in Italy there are approximately 1.5 million C/1 properties registered in the name of natural persons, with an average surface area of approximately 66 square metres. A lower limit would therefore allow the benefit to be concentrated on properties intended for small commercial activities.
The crux of the discount on the fee
One of the points still to be defined concerns the relationship between tax relief and rent. Confcommercio has asked to link access to the coupon to a reduction in the rent agreed between the owner and tenant.
According to the association, this condition would make the benefit more effective for shopkeepers, artisans, bars and restaurateurs. The reduction in rent could in fact reduce the cost of rent and encourage the reopening of vacant premises. The objective is to support local trade and combat the desertification of historic centers and suburbs.
Confedilizia, on the other hand, looks with caution at the possibility of imposing a discount on the rent by law. The association recalls that the coupon would already entail for the owner the waiver of the ISTAT adjustment of the rent for the entire duration of the contract. In commercial leases, the term is generally six years plus six.
Furthermore, since this is a benefit intended for new contracts, the market could independently lead the owners to propose more favorable economic conditions.
Rentals to businesses, the application of the coupon remains to be defined
The question of the application of the tax rate when the tenant is a company also remains open. The enabling law for the tax reform had provided for the possibility of extending the subsidized regime to the rental of properties intended for uses other than residential, when the tenant carries out a business activity, an art or a profession. However, the forecast has not yet been definitively implemented.
The topic has been the subject of a long dispute, especially for residential properties rented to companies as guesthouses for employees or managers. The United Sections of the Court of Cassation are called upon to clarify the scope of the coupon in contracts in which the tenant is not a natural person acting for private needs.
The decision could also have consequences on the drafting of the new law relating to commercial properties.
