Response no. 77/2026 of the Italian Revenue Agency addresses the case of cash payment for revenue stamps exceeding 500 euros, excluding in such case the two-year reduction of assessment terms provided for by Article 3 of Legislative Decree no. 127/2015. At the same time, the document offers a useful opportunity to draw attention to an incentive scheme which, if properly managed, still retains significant practical relevance today.
The case examined by the Agency
The application was submitted by a company intending to make cash payments exceeding 500 euros for the purchase of revenue stamps, without issuing electronic invoices or certification through electronic receipts. The taxpayer argued that such circumstances should not compromise access to the reduction of assessment terms, considering that the purchase of revenue stamps, being VAT-exempt, could not fall within the notion of “transaction” referred to in Article 3 of Legislative Decree no. 127/2015. The Italian Revenue Agency rejected this interpretation, clarifying that “transactions exceeding 500 euros” to be carried out using traceable instruments must include all activities performed by VAT taxpayers in the course of business or professional activities, including the purchase of revenue stamps. Consequently, cash payment exceeding the prescribed threshold constitutes in itself conduct incompatible with the benefit of the two-year reduction of assessment terms.
Beyond the unfavorable conclusion reached in the specific case, response no. 77/2026 is of broader interest, as it draws attention to a benefit that continues to represent a particularly significant instrument for taxpayers who adopt a fully transparent documentary and financial structure.
A benefit not to be overlooked
Specifically, Article 3 of Legislative Decree no. 127/2015 provides for a two-year reduction of the limitation period referred to in Article 57, first paragraph, of Presidential Decree 633/72 and the limitation period referred to in Article 43, first paragraph, of Presidential Decree 600/73. The Agency’s response under review provides a detailed summary of the requirements set forth by the regulatory framework, as well as by the implementing decree, Ministerial Decree of 4 August 2016 of the Ministry of Economy and Finance. First, the benefit applies to VAT taxpayers for supplies of goods and services carried out between parties resident or established in the territory of the State. Second, all active transactions must be documented through electronic invoicing via the Exchange System and/or through electronic storage and electronic transmission of daily receipts. In addition, there is an obligation to ensure traceability of payments received and those made for transactions exceeding 500 euros. Finally, the taxpayer must indicate in the relevant annual income tax return the existence of the requirements for the reduction of limitation periods; failing this, the reduction remains ineffective.
Traceability alone is not sufficient
The Agency further reiterates that traceability of payments alone is not, in itself, sufficient to access the benefit. It must be accompanied by proper compliance with the obligations to document active transactions, without prejudice to the exclusion from the incentive scheme for those who, although exempt from certification obligations, do not adopt them voluntarily.