With the entry into force of the 2026 Budget Law, among the significant measures set to affect the current framework of tax relations is the introduction of the so-called “Rottamazione-quinquies”. This is a new facilitated settlement scheme for tax debts entrusted for collection to the Italian Revenue Agency – Collection (AdER), designed to offer taxpayers and businesses a concrete tool for settling outstanding tax liabilities, with opportunities not yet fully explored in public debate.

Rome, January 15, 2026

Rottamazione-quinquies: what is it?

The Rottamazione-quinquies is a facilitated settlement scheme for debts entrusted to the Italian Revenue Agency – Collection (AdER) covering the period from January 1, 2000 to December 31, 2023. This is essentially the fifth edition of a tax relief mechanism now well established in practice, which allows taxpayers to settle outstanding debts without the burden of penalties, late-payment interest, and collection fees, by paying only the original principal amount due and, in some cases, the actual costs of notification or collection.

Main changes in 2026

Compared to previous editions of the settlement scheme, the “quinquies” includes some notable specific features:

1. Broader reference period

The measure covers a multi-year period (2000-2023), making it possible to settle tax bills entrusted for collection over a long historical span, with a potentially significant impact for many taxpayers who did not take part in previous editions.

2. Only debts from unpaid taxes

The following debts arising from non-payment can be settled:

• Taxes resulting from annual tax returns and from the activities of the tax authorities under Articles 36-bis and 36-ter of Presidential Decree No. 600 of 1973, and Articles 54-bis and 54-ter of Presidential Decree No. 633 of 1972
• Social security contributions owed to INPS, excluding those arising from a tax assessment.

Excluded, however, are tax debts arising from assessments currently under dispute.

3. How to submit the application

The declaration of participation must be submitted exclusively online, using the channels made available by the Italian Revenue Agency – Collection, by April 30, 2026.

4. Payment options and timeline

With the Rottamazione-quinquies, taxpayers can choose between:

• Payment in a single installment by July 31, 2026
• A payment plan divided into 54 bimonthly installments (i.e., a total period of up to 9 years). This installment option carries annual interest of 3% on the amounts due starting from August 1, 2026.

This structure offers significant flexibility in managing cash flow, with set deadlines and sustainable medium-term planning.

5. Forfeiture of benefits

Under the provisions of the 2026 Budget Law, the benefits of this measure will be forfeited in the event of non-payment or insufficient payment of the chosen installment, whether in the case of a single lump-sum payment or an installment plan.

If the installment plan is chosen, the tax benefits will be lost in the following cases:

1. Failure to pay two installments, even if not consecutive

2. Failure to pay the last installment of the payment plan

Key aspects to keep under control

The Rottamazione-quinquies is more than just a temporary window of opportunity. It is a genuine opportunity for settlement that requires careful attention to the operating conditions:

• Determine which tax bills can be included, since not all outstanding debts are automatically eligible for settlement, with tax debts arising from tax and social security assessments not entrusted to collection agents being excluded.
• Correctly calculate the amount eligible for settlement, taking into account any notification and procedural costs, despite the waiver of penalties and interest.
• Choose the most suitable installment plan, since the option to spread payments over up to 9 years can be beneficial, but it requires financial discipline to avoid forfeiting the benefits.

Rottamazione-quinquies: managing it the right way

The Rottamazione-quinquies introduced by the 2026 Budget Law represents a particularly significant tool for taxpayers and businesses looking to reorganize their relationship with the tax authorities, especially where debt positions have built up over time. However, correctly identifying the debts eligible for settlement, assessing the financial impact of the available payment options, and managing deadlines require careful technical analysis, in order to avoid mistakes that could jeopardize access to the benefits provided for under the law.

In this regard, Santoro & Partners supports businesses and professionals in interpreting and applying facilitated settlement measures, offering qualified assistance in assessing individual debt positions and planning the solutions best suited to each taxpayer’s tax and financial situation. This approach makes it possible to turn a regulatory obligation into an opportunity to rebalance and streamline one’s overall tax position.