Art. 1(48) of Law No. 207/2024 (2025 Budget Law) establishes that, for the purpose of calculating the monetary value of fringe benefits arising from the private use of:
- cars, mixed-use vehicles (art. 54(1)(a), (c) and (m) of Legislative Decree No. 285/1992), motorcycles and mopeds,
- newly registered,
- granted to the employee for mixed (personal and work-related) usage under a contract entered into after 31 December 2024,
50% of the amount corresponding to a conventional mileage of 15,000 km, calculated based on ACI (Automobile Club Italia) cost-per-km tables (art. 51(4)(a) of the TUIR), must be considered as taxable income.
Additionally, for specific types of vehicles, the value of the benefit in kind is further reduced to:
- 20% for plug-in hybrid electric vehicles,
- 10% for fully electric battery vehicles.
Due to its brevity and lack of clarity, the original rule raised several interpretative doubts. Although its literal reading left little room for alternative interpretations, the practical implementation of the new tax and social security regime required further legislative clarification. This clarification came — somewhat late — with the introduction of art. 1(48-bis) of Law No. 207/2024, inserted during the conversion of Decree-Law No. 19/2025 (via Law No. 60/2025, in force from 30 April 2025).
Under the new provision, the previous tax regime (as of 31 December 2024) remains applicable to vehicles:
- granted for mixed use between 1 July 2020 and 31 December 2024,
- ordered by the employer by 31 December 2024 and granted for mixed use to the employee between 1 January and 30 June 2025.
In such cases, the taxable value of the benefit is a set percentage of the amount corresponding to a conventional mileage of 15,000 km (2025 rates were published in the Official Gazette – Supplement – on 30 December 2024, No. 304). More precisely:
- 25% of the value determined by ACI, for cars with Co2 emissions up to 60g/km,
- 30% for cars with Co2 emissions between 60g/km and 160g/km,
- 50% for cars with Co2 emissions between 160g/km and 190g/km,
- 60% for cars with Co2 emissions in excess of 190g/km.
Current taxation scenarios may therefore be recapped as follows:
- Vehicles ordered and granted for mixed use between 1 July 2020 and 31 December 2024 → 25/30/50/60% rule applies.
- Vehicles ordered by 31 December 2024 and granted between 1 January and 30 June 2025 → 25/30/50/60% rule applies.
- Vehicles ordered from 1 January 2025 and granted from the same date → new regime applies (50%, 20%, or 10%).
- Vehicles registered before 31 December 2024 but granted for use from 1 January 2025 → uncertain: not explicitly covered by the new rule.
Given the complexity of the current regulatory framework, a prompt clarification by the Italian Revenue Agency is strongly recommended, particularly regarding:
- the procedures and deadlines for reconciling amounts already paid in terms of i) mandatory contributions and ii) tax withholdings under the regime in force from 1 January 2025,
- the tax treatment applicable to scenario no. 4, as the legislative amendment does not consider the vehicle registration date. In this case, it may be reasonable to rely on Resolution No. 46/2020, which states that the taxable value should reflect only the private use of the vehicle, excluding the part used for business purposes.
We remain available for any further clarification.