By resolution No. 22/2026, the Financial Administration has intervened on the substitute tax regime applicable to performance bonuses paid during 2026.
Art. 1(8,9) of Law No. 199/2025 (2026 Budget Law) provides that, in relation to performance bonuses paid during 2026 and 2027, the substitute tax for IRPEF income tax and regional and municipal surcharges, introduced by art. 1(182) of Law No. 208/2015, applies, unless formally waived by the worker, up to an overall limit of EUR 5,000.00 and at the reduced rate of 1 per cent.
Following certain interpretative doubts concerning the scope of application of the above provision, the Revenue Agency clarified that said taxable threshold also applies where the worker exercises the option to receive the bonus in the form of benefits provided by the employer, as per art. 1(184) of Law No. 208/2015.
The substitute tax regime applies provided that variable-amount performance bonuses are paid by reason of increases in i) productivity, ii) profitability, iii) quality, iv) efficiency and v) innovation (art. 1, para. 182, of Law No. 208/2015 and Ministry of Labour, Ministerial Decree of 25 March 2016).
We remain available for any further clarification.