Il DL 26.10.2019 n. 124 (c.d. “decreto fiscale collegato alla legge di bilancio 2020” è stato convertito nella L. 19.12.2019 n. 157 (pubblicata sulla G.U. 24.12.2019 n. 301), prevedendo numerose novità rispetto al testo originario.
Di seguito si riepilogano le principali novità in ambito fiscale contenute nel DL 26.10.2019 n. 124, conv. L. 19.12.2019 n. 157, ad eccezione delle novità in materia di diritto penale tributario, che sono analizzate nel successivo § 4.
Argomento | Descrizione |
Versamento delle ritenute fiscali e dei contributi nell’ambito dei contratti di appalto o di prestazione di opere e servizi |
L’art. 4 del DL 124/2019 convertito ha introdotto il nuovo art. 17-bis nel DLgs. 241/97, che deroga al precedente art. 17 co. 1 in materia di versamenti e compensazioni.
Il testo originario della norma, che è stato integralmente modificato durante l’iter di conversione, aveva introdotto un complesso meccanismo che attribuiva al committente, di regola, la responsabilità del versamento delle ritenute fiscali (sia a titolo di IRPEF che delle relative addizionali) trattenute dall’impresa appaltatrice o affidataria e dalle imprese subappaltatrici ai lavoratori direttamente impiegati nell’esecuzione dell’opera o del servizio, garantendo che la provvista per il versamento delle stesse fosse messa a disposizione dal datore di lavoro, oppure mediante compensazione con i corrispettivi maturati a favore delle imprese appaltatrici o affidatarie e non ancora corrisposti. Nella formulazione attuale, invece, la norma prevede che spetti alle imprese appaltatrici, affidatarie e subappaltatrici l’obbligo di versare le ritenute sui redditi di lavoro dipendente e assimilati per i lavoratori impiegati nell’esecuzione dell’opera o del servizio, senza poterle compensare nel modello F24 con proprie posizioni creditorie, se eseguono opere o servizi per un importo complessivo annuo superiore a 200.000,00 euro da realizzare con prevalente utilizzo di manodopera. Il committente, invece, ha l’obbligo di controllare che l’impresa adempia al versamento delle ritenute e, se rileva un inadempimento, deve sospendere il pagamento dei corrispettivi e comunicarlo all’Agenzia delle Entrate competente. Ambito soggettivo La norma si applica ai committenti che affidano il compimento di una o più opere o di uno o più servizi, che siano sostituti d’imposta e residenti ai fini delle imposte dirette nello Stato. Sono esclusi dalla disciplina in esame i committenti che non hanno la qualifica di sostituti d’imposta, ad esempio le persone fisiche che non agiscono nell’ambito di attività imprenditoriali o professionali (c.d. “privati”). Ambito oggettivo La deroga introdotta con l’art. 17-bis del DLgs. 241/97 si applica ai committenti che affidino ad un’impresa appaltatrice, affidataria o subappaltatrice l’esecuzione di una o più opere o di uno o più servizi per un importo complessivo annuo superiore a 200.000,00 euro, attraverso “contratti di appalto, subappalto, affidamento a soggetti consorziati o rapporti negoziali comunque denominati caratterizzati dal prevalente utilizzo di manodopera presso le sedi di attività del committente con l’utilizzo di beni strumentali di proprietà di quest’ultimo”. Per rientrare nell’ambito applicativo della disposizione devono coesistere: |
· sia il limite economico (importo annuo complessivo dell’opera o delle opere e del servizio o dei servizi commissionati superiore a 200.000,00 euro);
· sia quello relativo all’esecuzione, caratterizzato dalla prevalenza dell’utilizzo della manodopera presso le sedi di attività del committente con beni strumentali di quest’ultimo. Obblighi dell’impresa appaltatrice o affidataria e subappaltatrici L’impresa appaltatrice o affidataria e subappaltatrice: · determina e trattiene l’importo delle ritenute fiscali calcolate sui redditi di lavoro dipendente e assimilati corrisposti ai lavoratori impegnati nell’esecuzione dell’opera o del servizio per tutta la durata del contratto; · provvede al versamento delle medesime nel rispetto del termine ordinario, ma senza poterle compensare nel modello F24 con proprie posizioni creditorie. Nei 5 giorni lavorativi successivi rispetto alla scadenza del termine per il pagamento delle ritenute, l’impresa appaltatrice o affidataria e le imprese subappaltatrici trasmettono al committente, e per le imprese subappaltatrici, anche all’impresa appaltatrice: · i modelli F24 utilizzati per il pagamento delle ritenute sui redditi di lavoro dipendente e assimilati dei lavoratori impiegati nella prestazione dell’opera o del servizio affidatogli dal medesimo committente, compilati secondo le indicazioni contenute nella ris. Agenzia delle Entrate 24.12.2019 n. 109; · un elenco nominativo di tutti i lavoratori, indicandone anche il codice fiscale, impiegati nel mese precedente nell’esecuzione dell’opera o del servizio, con il dettaglio delle ore di lavoro prestate da ciascun lavoratore; · l’ammontare della retribuzione corrisposta a ciascun lavoratore impiegato nell’esecuzione dell’opera o del servizio affidato dal committente; · il dettaglio delle ritenute fiscali eseguite nel mese precedente per ciascun lavoratore, con separata indicazione delle ritenute relative alla prestazione affidata dal committente. Responsabilità dell’impresa appaltatrice, affidataria o subappaltatrice L’art. 17-bis del DLgs. 241/97 prevede che l’impresa appaltatrice, affidataria e subappaltatrice sia responsabile per la corretta determinazione e per la corretta esecuzione delle ritenute, nonché per il versamento delle medesime, senza possibilità di compensazione nel modello F24. Tale impresa è responsabile anche nel caso in cui non fornisca al committente i modelli F24 utilizzati per il versamento delle ritenute e i dati necessari per permettergli di verificare la corretta determinazione delle medesime. Obblighi del committente Il committente deve: · chiedere all’impresa appaltatrice o affidataria e alle imprese subappaltatrici la copia dei modelli F24 relativi al versamento delle ritenute, al fine di riscontrarne il corretto adempimento; · sospendere il pagamento dei corrispettivi maturati dall’impresa appaltatrice o affidataria, finché perdura l’inadempimento, fino alla concorrenza del 20% del valore complessivo dell’opera o del servizio o se inferiore per un importo pari all’ammontare delle ritenute non versate, nel caso in cui non riceva, entro i 5 giorni successivi al termine per il versamento, i modelli F24 utilizzati per il pagamento delle ritenute sui redditi di lavoro dipendente e assimilati dovute in relazione ai lavoratori impiegati nell’esecuzione dell’opera o del servizio, o nel caso in cui li abbia ricevuti ed abbia rilevato un omesso o insufficiente versamento; · comunicare l’inadempimento riscontrato all’Agenzia delle Entrate competente entro 90 giorni. |
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Responsabilità del committente
L’inadempimento degli obblighi previsti per il committente dall’art. 17-bis del Sanzioni per il committente L’art. 17-bis co. 4 del DLgs. 241/97 dispone che il committente inadempiente sia obbligato al pagamento di una somma pari alla sanzione irrogata all’impresa appaltatrice, affidataria e subappaltatrice per la violazione degli obblighi di: · corretta determinazione delle ritenute; · corretta esecuzione delle medesime; · tempestivo versamento delle ritenute senza possibilità di compensazione. La somma chiesta al committente si aggiunge alla sanzione irrogata per l’inadempimento dell’impresa appaltatrice, affidataria o subappaltatrice e non può essere pagata mediante compensazione nel modello F24. Ravvedimento operoso Il termine di 90 giorni previsto per il committente che, avendo riscontrato un inadempimento dell’impresa appaltatrice, affidataria o subappaltatrice deve comunicarlo all’Agenzia delle Entrate, permette alle medesime di avvalersi del ravvedimento per rimediare alla violazione commessa, potendo beneficiare della riduzione delle sanzioni ad un decimo se perfezionato entro 30 giorni dalla data della violazione e ad un nono se la regolarizzazione viene posta in essere entro 90 giorni dalla violazione commessa. L’impresa appaltatrice, affidataria o subappaltatrice può regolarizzare la violazione commessa anche dopo il termine dei 90 giorni, ma in tal caso il committente avrà comunicato l’inadempimento all’Agenzia delle Entrate. Pertanto, aumenta per l’impresa appaltatrice, affidataria o subappaltatrice il rischio di non poter ravvedere la violazione commessa, nel caso in cui venga notificato uno degli atti che inibiscono la facoltà di ravvedersi (es. atto di accertamento, irrogazione di sanzioni, cartella di pagamento). Contributi previdenziali e premi INAIL – Esclusione della compensazione Il nuovo art. 17-bis del DLgs. 241/97 prevede inoltre che le imprese appaltatrici o affidatarie e le imprese subappaltatrici devono versare, senza potersi avvalere della compensazione nel modello F24 con proprie posizioni creditorie, quanto dovuto per contributi previdenziali e assistenziali e premi assicurativi obbligatori maturati: · in relazione alle retribuzioni erogate ai dipendenti direttamente impiegati nell’esecuzione delle opere o dei servizi affidati; · nel corso di durata del contratto. Facoltà di disapplicazione della nuova disciplina L’impresa appaltatrice, affidataria e subappaltatrice disapplica l’art. 17-bis del DLgs. 241/97 (anche per i versamenti contributivi) se nell’ultimo giorno del mese precedente a quello previsto per il versamento delle ritenute soddisfa i seguenti requisiti: · risulti in attività da almeno 3 anni, sia in regola con gli obblighi dichiarativi e abbia eseguito nel corso dei periodi d’imposta cui si riferiscono le dichiarazioni dei redditi presentate nell’ultimo triennio versamenti complessivi registrati nel conto fiscale per un importo non inferiore al 10% dell’ammontare dei ricavi o compensi risultanti da tali dichiarazioni; · non abbia iscrizioni a ruolo o accertamenti esecutivi o avvisi di addebito affidati agli Agenti della Riscossione per imposte sui redditi, IRAP, ritenute e contributi previdenziali per importi superiori a 50.000,00 euro, per i quali siano ancora dovuti pagamenti o non vi siano provvedimenti di sospensione o piani di rateazione per i quali non sia intervenuta la decadenza. È previsto il rilascio di un certificato da parte dell’Agenzia delle Entrate che attesti il possesso dei richiamati requisiti e che ha validità di 4 mesi dal rilascio. Decorrenza Le nuove disposizioni si applicano a decorrere dall’1.1.2020, quindi dalle ritenute operate da tale data, anche con riferimento ai contratti stipulati prima del 1° gennaio (ris. Agenzia delle Entrate 23.12.2019 n. 108). Cessazione L’art. 2 del DL 124/2019 convertito prevede l’impossibilità di avvalersi della compensazione per i contribuenti nei confronti di quali sia stato notificato da parte dell’Agenzia delle Entrate: · il provvedimento di cessazione della partita IVA; · ovvero il provvedimento di esclusione della partita IVA dalla banca dati VIES. |
Compensazione nel modello F24 di crediti relativi a imposte dirette e IRAP – Obbligo di preventiva presentazione della dichiarazione | Per effetto dell’art. 3 co. 1 del DL 124/2019 convertito, l’obbligo di preventiva presentazione della dichiarazione per la compensazione nel modello F24 di crediti, per importi superiori a 5.000,00 euro annui, viene esteso:
· alle imposte sui redditi e relative addizionali; · alle imposte sostitutive delle imposte sui redditi; · all’IRAP. Tali crediti potranno quindi essere utilizzati in compensazione: · solo a seguito della presentazione del modello REDDITI o IRAP dal quale emergono; · a partire dal decimo giorno successivo a quello di presentazione della relativa dichiarazione. In pratica, vengono estese ai crediti relativi alle imposte sui redditi e all’IRAP le stesse regole già applicabili ai crediti IVA. |
Decorrenza
La nuova disciplina si applica con riferimento ai crediti maturati a decorrere dal periodo d’imposta in corso al 31.12.2019 (art. 3 co. 3 del DL 124/2019 convertito), quindi da quelli emergenti dai modelli REDDITI 2020 e IRAP 2020. Per i crediti maturati nel periodo d’imposta in corso al 31.12.2018, emergenti dai modelli REDDITI 2019 e IRAP 2019, rimangono invece applicabili le precedenti disposizioni che non prevedevano l’obbligo di preventiva presentazione della dichiarazione dalla quale emergono. |
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Presentazione dei modelli F24 contenenti compensazioni – Obbligo di utilizzare i servizi telematici dell’Agenzia delle Entrate – Estensione |
Per effetto dell’art. 3 co. 2 del DL 124/2019 convertito, viene esteso ai contribuenti non titolari di partita IVA l’obbligo di utilizzare i sistemi telematici messi a disposizione dall’Agenzia delle Entrate per la presentazione dei modelli F24 contenenti compensazioni, senza limiti di importo:
· di crediti relativi alle imposte sui redditi (IRPEF e IRES) e alle relative addizionali, alle imposte sostitutive delle imposte sul reddito e all’IRAP; · dei crediti d’imposta ai fini agevolativi da indicare nel quadro RU della dichiarazione dei redditi. In pratica, anche per i contribuenti non titolari di partita IVA l’utilizzo dei sistemi telematici dell’Agenzia delle Entrate per la presentazione dei modelli F24 contenenti compensazioni diventa un obbligo generalizzato, mentre prima era previsto solo in caso di modelli F24 “a saldo zero” o di particolari crediti d’imposta agevolativi. Crediti maturati in qualità di sostituto d’imposta L’obbligo di utilizzare i sistemi telematici messi a disposizione dall’Agenzia delle Entrate per la presentazione dei modelli F24 contenenti compensazioni viene esteso a tutti i crediti maturati in qualità di sostituto d’imposta (es. per ritenute alla fonte, rimborsi da modelli 730, “bonus Renzi”), indipendentemente dal possesso della partita IVA. Decorrenza La nuova disciplina si applica con riferimento ai crediti maturati a decorrere dal periodo d’imposta in corso al 31.12.2019 (art. 3 co. 3 del DL 124/2019 convertito), quindi, ad esempio, da quelli emergenti dai modelli REDDITI 2020 e IRAP 2020. |
Accollo fiscale con compensazione di crediti – Divieto | Per effetto dell’art. 1 del DL 124/2019 convertito, è vietato estinguere debiti tributari tramite il c.d. “accollo fiscale”, nel caso in cui il debito del contribuente accollato venga pagato non in contanti dall’accollante, bensì utilizzando in compensazione un credito d’imposta a disposizione dell’accollante.
Ove ciò avvenga, il pagamento si dà per non eseguito. Vengono inoltre previste sanzioni amministrative (e, eventualmente, anche penali) a carico dell’accollante e dell’accollato. In capo all’accollato viene recuperato il debito d’imposta, con responsabilità solidale dell’accollante. |
Controllo preventivo delle compensazioni – Scarto dei modelli F24 – Sanzioni |
L’Agenzia delle Entrate, se ravvisa profili di rischio dalla stessa individuati, può bloccare preventivamente i modelli F24 che contengono compensazioni e successivamente disporne lo scarto.
Se il modello F24 viene bloccato e scartato, il pagamento non è eseguito. Con l’art. 4 co. 5 – 8 del DL 124/2019 convertito si prevede una sanzione pari al 5% dell’importo per importi fino a 5.000,00 euro, oppure pari a 250,00 euro per importi superiori a 5.000,00 euro, a carico del contribuente il cui modello F24 sia stato preventivamente scartato (nella versione originaria del DL era prevista una sanzione fissa di 1.000,00 euro). Tale sanzione viene contestata mediante cartella di pagamento, con diretta iscrizione a ruolo. |
Ove il contribuente paghi la sanzione entro 30 giorni dall’apposita comunicazione preventiva inviata dall’Agenzia delle Entrate, l’iscrizione a ruolo non viene eseguita.
In ogni caso, il contribuente può far presente all’Agenzia delle Entrate elementi valutati erroneamente o non considerati. |
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Contrasto alle indebite compensazioni – Cooperazione tra Agenzia delle Entrate, INPS e INAIL |
Con l’art. 3 co. 4 del DL 124/2019 convertito viene previsto che l’Agenzia delle Entrate, l’INPS e l’INAIL definiscano procedure di cooperazione rafforzata finalizzate al contrasto delle indebite compensazioni di crediti effettuate ai sensi dell’art. 17 del DLgs. 241/97.
I suddetti Istituti possono infatti inviare all’Agenzia delle Entrate segnalazioni qualificate relative a compensazioni di crediti effettuate ai fini del pagamento delle entrate di rispettiva pertinenza: · che presentano profili di rischio; · ai fini del recupero del credito indebitamente compensato. Provvedimenti attuativi Le procedure in esame e ogni altra disposizione attuativa saranno definite con provvedimenti adottati d’intesa dal Direttore dell’Agenzia delle Entrate e dai Presidenti di INPS e INAIL. |
Compensazione crediti commerciali verso Pubbliche Amministrazioni con somme iscritte a ruolo – Proroga per il 2019 e 2020 |
Con l’art. 37 co. 1-bis del DL 124/2019 convertito, viene estesa anche agli anni 2019 e 2020 la possibilità, per le imprese e i lavoratori autonomi, di utilizzare in compensazione, con le somme dovute a seguito di iscrizione a ruolo o derivanti da atti esecutivi, affidate agli Agenti della Riscossione entro il 31.10.2019, i crediti:
· maturati nei confronti della Pubblica Amministrazione; · relativi a somministrazioni, forniture, appalti e servizi, anche professionali; · non prescritti, certi, liquidi ed esigibili, che sono stati oggetto di apposita certificazione da parte dell’Ente debitore. La nuova modalità di compensazione dei crediti commerciali e professionali può quindi essere esercitata: · a decorrere dal 25.12.2019 (data di entrata in vigore della L. 157/2019) e fino al 31.12.2020; · in relazione a tributi erariali, regionali e locali, contributi previdenziali e assistenziali, premi per l’assicurazione obbligatoria contro gli infortuni sul lavoro e le malattie professionali, entrate spettanti all’Ente che ha rilasciato la certificazione, nonché per gli oneri accessori, gli aggi e le spese a favore dell’Agente della Riscossione, relativi ai carichi affidati entro il 31.10.2019; · qualora la somma affidata all’Agente della Riscossione sia inferiore o pari al credito vantato; · su richiesta del creditore, che dovrà presentare all’Agente della Riscossione competente la certificazione del credito rilasciata dalla Pubblica Amministrazione debitrice. |
Modifica della misura delle rate degli acconti IRPEF, IRES e IRAP |
L’art. 58 del DL 124/2019 convertito modifica, a regime, la misura della prima e seconda rata degli acconti dell’IRPEF, dell’IRES, dell’IRAP e delle relative addizionali e imposte sostitutive, dovuti dai contribuenti soggetti agli indici sintetici di affidabilità fiscale (ISA).
In luogo degli attuali 40% (prima rata) e 60% (seconda rata) dell’importo complessivamente dovuto, dal 2020 occorrerà versare due rate di pari importo (ognuna del 50%). La disposizione ha effetto anche sul periodo d’imposta in corso al 31.12.2019 (2019, per i soggetti “solari”), con una riduzione, di fatto, della misura dell’acconto complessivamente dovuto al 90% (85,5% per la cedolare secca sulle locazioni ex art. 3 del DLgs. 23/2011). |
Soggetti interessati dalla modifica
La modifica interessa soltanto i contribuenti che, contestualmente (art. 12-quinquies co. 3 e 4 del DL 34/2019 e ris. Agenzia delle Entrate 12.11.2019 n. 93): · esercitano attività d’impresa o di lavoro autonomo per le quali sono stati approvati gli ISA, a prescindere dal fatto che tale metodologia statistica sia stata concretamente applicata; · dichiarano ricavi o compensi di ammontare non superiore al limite stabilito, per ciascun ISA, dal relativo decreto ministeriale di approvazione (attualmente pari a 5.164.569,00 euro). Ricorrendo tali condizioni, risultano interessati dalla modifica anche i contribuenti che: · partecipano a società, associazioni e imprese con i suddetti requisiti e che devono dichiarare redditi “per trasparenza”, ai sensi degli artt. 5, 115 e 116 del TUIR; · applicano il regime forfetario di cui all’art. 1 co. 54 ss. della L. 190/2014; · applicano il regime di vantaggio di cui all’art. 27 co. 1 e 2 del DL 98/2011 (c.d. “contribuenti minimi”); · determinano il reddito con altre tipologie di criteri forfetari; · ricadono nelle altre cause di esclusione dagli ISA. Per gli altri contribuenti, resta ferma l’attuale bipartizione (prima rata al 40% e seconda rata al 60%), sia per il 2019, sia per gli anni successivi. Imposte interessate dalla modifica La modifica delle rate di acconto si estende, oltre che all’IRPEF, all’IRES e all’IRAP (espressamente citate dalla norma), anche all’imposta sostitutiva per il regime forfetario e alle altre imposte sostitutive per le quali si applicano i criteri IRPEF di versamento dell’acconto, quali, ad esempio: · la cedolare secca di cui all’art. 3 del DLgs. 23/2011; · I’IVAFE di cui all’art. 19 co. 18 – 22 del DL 201/2011; · l’IVIE di cui all’art. 19 co. 13 – 17 del DL 201/2011. Effetti sugli acconti relativi al 2019 Per i citati soggetti ISA, riguardo al periodo d’imposta in corso al 31.12.2019 (2019, per i soggetti “solari”): · resta “salva” la prima rata di acconto versata in misura pari al 40% (non occorre, quindi, in ogni caso integrare il pagamento a suo tempo effettuato); · la seconda rata è dovuta nella misura del 50%; · in caso di versamento in un’unica soluzione entro il termine per il versamento della seconda rata, l’acconto è dovuto in misura pari al 90% (85,5% per la cedolare secca). Per gli altri contribuenti restano ferme le “vecchie” modalità. Effetti sugli acconti a regime A partire dal periodo d’imposta in corso al 31.12.2020 (2020, per i soggetti “solari”), la prima e la seconda rata di acconto saranno dovute in misura differente per i contribuenti ISA, da un lato, e per i contribuenti estranei agli ISA, dall’altro, ferma restando la misura complessivamente dovuta (pari, nella generalità dei casi, al 100%, fatta eccezione per la cedolare secca il cui acconto, ancora per il 2020, sarà dovuto nella misura del 95%). In particolare, per i soggetti ISA: · sia la prima che la seconda rata di acconto saranno dovute nella misura del 50%; · se l’importo della prima rata non supera 103,00 euro, l’acconto sarà versato in un’unica soluzione entro il termine per il versamento della seconda rata. Per gli altri soggetti, restano ferme le “vecchie” modalità. |
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Tassazione dei dividendi percepiti da società semplici |
Con l’art. 32-quater del DL 124/2019 convertito è stato previsto che i dividendi corrisposti alle società semplici si intendono percepiti per trasparenza dai rispettivi soci, con conseguente applicazione del corrispondente regime fiscale.
Questa norma si applica per i dividendi distribuiti alle società semplici, in qualsiasi forma e sotto qualsiasi denominazione, anche in caso di recesso, di esclusione, di riscatto e di riduzione del capitale esuberante o di liquidazione anche concorsuale della società. Pertanto: · per la quota imputabile ai soggetti IRES che applicano l’art. 89 del TUIR, i dividendi sono esclusi dalla formazione del reddito complessivo per il 95% del loro ammontare; · per la quota imputabile alle imprese individuali ed alle società di persone commerciali, i dividendi sono esclusi dalla formazione del reddito complessivo, nella misura del 41,86% del loro ammontare, nell’esercizio in cui sono percepiti; · per la quota imputabile alle persone fisiche residenti in relazione a partecipazioni, qualificate e non qualificate, non relative all’impresa, i dividendi sono soggetti a tassazione con applicazione di una ritenuta a titolo d’imposta del 26%. La ritenuta a titolo d’imposta menzionata nell’ultimo punto deve essere operata dalle società e dagli enti commerciali residenti sulla base delle informazioni fornite dalla società semplice. Evoluzione della disciplina Prima delle modifiche apportate dalla L. 145/2018 (legge di bilancio 2019), i dividendi concorrevano parzialmente alla formazione del reddito della società, poi imputato per trasparenza al socio, nella misura: · del 58,14% del loro ammontare, in relazione agli utili prodotti a partire dall’esercizio successivo a quello in corso al 31.12.2016; · del 49,72% del loro ammontare, se gli utili si sono formati a partire dall’esercizio successivo a quello in corso al 31.12.2007 fino all’esercizio in corso al 31.12.2016; · del 40% del loro importo, se gli utili sono stati prodotti prima dell’esercizio successivo a quello in corso al 31.12.2007. Tuttavia, a seguito dell’abrogazione del primo periodo del co. 1 dell’art. 47 del TUIR ad opera della legge di bilancio 2019, gli utili percepiti dalla società semplice dovevano considerarsi integralmente tassabili. Con il DL 124/2019 convertito viene quindi nuovamente reso coerente il regime dei dividendi conseguiti da una società semplice, considerando i medesimi percepiti dai soci di quest’ultima con l’applicazione del corrispondente regime fiscale. |
Consegna e trasmissione telematica delle certificazioni del sostituto d’imposta – Nuovi termini dal 2021 |
Per effetto dell’art. 16-bis co. 2 del DL 124/2019 convertito, dal 2021 viene stabilito al 16 marzo il termine per:
· la consegna al contribuente delle certificazioni del sostituto d’imposta; · la trasmissione telematica all’Agenzia delle Entrate delle Certificazioni Uniche. Certificazioni Uniche non rilevanti per la precompilata Rimane ferma la scadenza del 31 ottobre per la trasmissione telematica all’Agenzia delle Entrate delle Certificazioni Uniche non rilevanti per la predisposizione delle dichiarazioni precompilate. Certificazioni relative al periodo d’imposta 2019 Le certificazioni relative al 2019 dovranno quindi ancora essere: · inviate in via telematica all’Agenzia delle Entrate entro il 9.3.2020 (in quanto il 7 marzo cade di sabato); · consegnate ai contribuenti entro il 31.3.2020. |
Trasmissione telematica dei dati per la precompilazione delle dichiarazioni – Nuovi termini dal 2021 |
Per effetto dell’art. 16-bis co. 4 del DL 124/2019 convertito, dal 2021 viene prorogato al 16 marzo il termine del 28 febbraio stabilito per la trasmissione telematica all’Agenzia delle Entrate dei dati relativi agli oneri deducibili e detraibili da utilizzare per la precompilazione delle dichiarazioni dei redditi.
Messa a disposizione della dichiarazione precompilata Conseguentemente, sempre dal 2021, il termine per la messa a disposizione della dichiarazione precompilata da parte dell’Agenzia delle Entrate viene differito dal 15 al 30 aprile. Comunicazione dei dati relativi al periodo d’imposta 2019 Le comunicazioni in via telematica dei dati relativi al periodo d’imposta 2019 devono quindi ancora essere effettuate entro: · il 31.1.2020, in relazione alle spese sanitarie; · il 28.2.2020 (non rileva l’anno bisestile), in relazione agli altri oneri deducibili o detraibili (comprese le spese veterinarie). |
Presentazione e trasmissione telematica dei modelli 730 ed effettuazione dei conguagli – Nuovi termini dal 2021 |
Per effetto dell’art. 16-bis co. 1 e 3 del DL 124/2019 convertito, dal 2021 vengono previsti nuovi termini in relazione ai modelli 730.
Presentazione dei modelli 730 – Nuovo termine dal 2021 A decorrere dal 2021, il termine di presentazione del modello 730 viene stabilito al 30 settembre, indipendentemente dalla modalità di presentazione (presentazione diretta, al sostituto d’imposta che presta assistenza fiscale, ad un CAF-dipendenti o professionista abilitato). Presentazione dei modelli 730/2020 I modelli 730/2020, relativi al periodo d’imposta 2019, devono quindi ancora essere presentati entro il: · 7.7.2020, in caso di presentazione al sostituto d’imposta che presta assistenza fiscale; · 23.7.2020, in caso di presentazione diretta da parte del contribuente o mediante un CAF-dipendenti o un professionista abilitato. Trasmissione telematica dei modelli 730 – Nuovi termini dal 2021 A decorrere dal 2021, i CAF-dipendenti e i professionisti abilitati, nonché i sostituti d’imposta che prestano assistenza fiscale, devono trasmettere i modelli 730 all’Agenzia delle Entrate entro: · il 15 giugno, per le dichiarazioni presentate dal contribuente entro il 31 maggio; · il 29 giugno, per le dichiarazioni presentate dal contribuente dal 1° al 20 giugno; · il 23 luglio, per le dichiarazioni presentate dal contribuente dal 21 giugno al 15 luglio; · il 15 settembre, per le dichiarazioni presentate dal contribuente dal 16 luglio al 31 agosto; · il 30 settembre, per le dichiarazioni presentate dal contribuente dal 1° al 30 settembre. Entro gli stessi termini devono essere trasmessi all’Agenzia delle Entrate anche i modelli 730-4 per l’effettuazione dei conguagli. Trasmissione telematica dei modelli 730/2020 I modelli 730/2020, relativi al periodo d’imposta 2019, devono quindi ancora essere trasmessi in via telematica all’Agenzia delle Entrate: · da parte del sostituto d’imposta che presta assistenza fiscale, entro il 7.7.2020; · da parte dei CAF-dipendenti e dei professionisti abilitati, entro: – il 29.6.2020, per le dichiarazioni presentate dal contribuente entro il 22 giugno; |
– il 7.7.2020, per le dichiarazioni presentate dal contribuente dal 23 al 30 giugno;
– il 23.7.2020, per le dichiarazioni presentate dal contribuente dal 1° al 23 luglio. Consegna al contribuente della copia del modello 730 elaborato Resta fermo che, prima della trasmissione telematica del modello 730 all’Agenzia delle Entrate, i CAF-dipendenti, i professionisti abilitati e i sostituti d’imposta che prestano assistenza fiscale devono consegnare al contribuente la copia del modello 730 elaborato e del relativo prospetto di liquidazione (modello 730-3). Effettuazione dei conguagli in capo al contribuente Per effetto dei nuovi termini di trasmissione telematica dei modelli 730 e 730-4, dal 2021 vengono ridefinite anche le scadenze per l’effettuazione in capo al contribuente, da parte del sostituto d’imposta, dei conguagli (a debito o a credito) derivanti dai modelli 730. Le somme risultanti a debito dal prospetto di liquidazione saranno infatti trattenute sulla prima retribuzione utile e comunque sulla retribuzione di competenza del mese successivo a quello in cui il sostituto d’imposta ha ricevuto il prospetto di liquidazione (ovvero secondo mese successivo per i pensionati). Analogamente, le somme risultanti a credito saranno rimborsate sulla prima retribuzione utile e comunque sulla retribuzione di competenza del mese successivo a quello in cui il sostituto d’imposta ha ricevuto il prospetto di liquidazione. |
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Ravvedimento operoso – Limiti temporali | Per effetto dell’art. 10-bis del DL 124/2019 convertito, viene estesa a tutti i comparti impositivi la possibilità di eseguire il ravvedimento operoso senza limitazioni temporali, entro, quindi, i termini di decadenza per la notifica dell’atto impositivo.
Ciò vale, in particolar modo, per i tributi locali e per tutte le entrate che hanno natura tributaria, come i contributi consortili. In precedenza, il ravvedimento operoso, per i tributi diversi da quelli amministrati dall’Agenzia delle Entrate, dai tributi doganali e dalle accise, doveva avvenire entro il termine di presentazione della dichiarazione dell’anno in cui è stata commessa la violazione o entro l’anno dalla violazione stessa. Rimane fermo che, per i tributi diversi da quelli amministrati dall’Agenzia delle Entrate, dai tributi doganali e dalle accise, il ravvedimento operoso rimane inibito dall’inizio di un controllo fiscale, ad esempio dalla notifica di un questionario o da un accesso. |
Interessi fiscali – Rimodulazione | L’art. 37 co. 1-ter e 1-quater del DL 124/2019 convertito prevede una generale rimodulazione dei tassi di interesse previsti dalla legislazione fiscale, ad oggi fissati dal DM 21.5.2009.
Nello specifico, il tasso di interesse per il versamento, la riscossione e i rimborsi di ogni tributo è determinato, nel rispetto degli equilibri di finanza pubblica, in misura compresa tra lo 0,1% e il 3%. Provvedimento attuativo Nel rispetto di tali limiti, i tassi applicabili dovranno essere individuati con decreto del Ministero dell’Economia e delle Finanze. |
“Rottamazione dei ruoli” – Versamento delle somme dovute o della prima rata – Proroga al 2.12.2019 |
In base all’art. 3 del DL 119/2018, era possibile aderire alla c.d. “rottamazione dei ruoli” consegnati agli Agenti della Riscossione dall’1.1.2000 al 31.12.2017, beneficiando in questo modo dello stralcio di sanzioni amministrative e interessi di mora.
La domanda andava presentata entro il 30.4.2019, termine prorogato al 31.7.2019 per determinate categorie di contribuenti. Coloro i quali hanno presentato domanda entro il 30.4.2019, avrebbero dovuto pagare la prima rata o tutte le somme entro il 31.7.2019, mentre coloro i quali hanno presentato la domanda entro il 31.7.2019 avrebbero dovuto pagare la prima rata o tutte le somme entro il 2.12.2019 (in quanto il 30 novembre cadeva di sabato). |
Per evitare questa disparità di termini, l’art. 37 del DL 124/2019 convertito stabilisce il differimento, senza indennità di mora, del termine di pagamento della prima rata (o di tutte le somme) dal 31.7.2019 al 2.12.2019.
Si evidenzia inoltre che: · la proroga dal 31.7.2019 al 2.12.2019 riguarda anche coloro i quali hanno pagato, entro il 7.12.2018, le rate pregresse, e che, per questa ragione, hanno avuto automatico accesso alla ridilazione del debito, previa nuova liquidazione degli importi ad opera dell’Agente della Riscossione; · per i soggetti che possono beneficiare della proroga del pagamento della prima rata, non muta il termine di pagamento della seconda, anch’esso scadente il 2.12.2019. |
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Imponibilità IVA delle prestazioni per le patenti di guida B e C1 | L’art. 32 co. 1 del DL 124/2019 convertito esclude dal regime di esenzione IVA, previsto per la generalità dei servizi didattici, le prestazioni relative all’insegnamento della guida automobilistica ai fini dell’ottenimento delle patenti di guida per i veicoli delle categorie B e C1.
Efficacia La disposizione ha efficacia dall’1.1.2020. Salvaguardia dei comportamenti pregressi Sono fatti salvi i comportamenti difformi adottati dai contribuenti anteriormente alla data di entrata in vigore della disposizione, per effetto della sentenza della Corte di Giustizia UE 14.3.2019 causa C-449/17. Certificazione dei corrispettivi L’art. 32 co. 4 del DL 124/2019 convertito stabilisce, a decorrere dall’1.1.2020, l’abolizione dell’esonero dall’obbligo di certificazione fiscale di cui potevano beneficiare le prestazioni didattiche, finalizzate al conseguimento della patente, rese dalle autoscuole. Per le suddette prestazioni, le autoscuole: · sono tenute alla memorizzazione elettronica e trasmissione telematica dei dati dei corrispettivi giornalieri ai sensi dell’art. 2 co. 1 del DLgs. 127/2015; · possono, fino al 30.6.2020, documentare i corrispettivi mediante il rilascio della ricevuta fiscale ovvero dello scontrino fiscale. |
Utilizzo dei file delle fatture elettroniche |
L’art. 14 del DL 124/2019 convertito modifica l’art. 1 del DLgs. 127/2015, prevedendo la memorizzazione integrale dei file delle fatture elettroniche sino al 31 dicembre dell’ottavo anno successivo a quello della dichiarazione cui i documenti si riferiscono o alla definizione di eventuali giudizi. Sulla base della nuova disposizione, l’Amministrazione finanziaria potrà, quindi, memorizzare anche i dati richiesti dall’art. 21 co. 2 lett. g) del DPR 633/72, concernenti la natura, qualità e quantità dei beni e servizi che formano oggetto dell’operazione, anche in caso di mancata adesione del contribuente al servizio di consultazione delle fatture elettroniche.I dati così ottenuti potranno essere utilizzati:· dalla Guardia di Finanza per l’assolvimento di funzioni di politica economica e finanziaria ad essa demandate; vengono potenziate, in questo modo, le attività di contrasto a violazioni non necessariamente relative al settore tributario (mercato dei capitali, tutela della proprietà intellettuale, ecc.);· dall’Agenzia delle Entrate e dalla Guardia di Finanza nell’ambito delle attività di analisi del rischio di evasione fiscale.In sede di attuazione delle nuove disposizioni, la Guardia di Finanza e l’Agenzia delle Entrate sono comunque tenute ad adottare “idonee misure di garanzia a tutela dei diritti e delle libertà dell’interessato”, sentito il Garante per la protezione dei dati personali. |
Restano ferme le disposizioni speciali in tema di fatturazione elettronica, anche con riguardo alla memorizzazione, conservazione e consultazione delle e-fatture, relative alle operazioni destinate agli organismi di informazione per la sicurezza della Repubblica (DIS, AISE, AISI). | |
Prestazioni sanitarie nei confronti di persone fisiche – Proroga del divieto di emissione di fatture elettroniche |
Non essendo ancora state individuate modalità specifiche per l’emissione della fattura elettronica da parte dei soggetti che effettuano prestazioni sanitarie nei confronti delle persone fisiche, l’art. 15 del DL 124/2019 convertito ha disposto la proroga, anche per l’anno 2020, del divieto di emissione di fattura elettronica mediante il Sistema di Interscambio da parte dei soggetti tenuti all’invio dei dati al Sistema tessera sanitaria con riferimento alle fatture i cui dati sono da inviare a tale Sistema (art. 10-bis del DL 23.10.2018 n. 119).Per effetto delle disposizioni contenute nell’art. 9-bis co. 2 del DL 14.12.2018 n. 135, la proroga ha effetto anche con riferimento alle fatture relative alle prestazioni sanitarie rese nei confronti delle persone fisiche da parte dei soggetti che non sono tenuti all’invio dei dati al Sistema tessera sanitaria.Il “decreto fiscale” stabilisce altresì che, a decorrere dall’1.7.2020, i soggetti tenuti all’invio dei dati al Sistema tessera sanitaria adempiono all’obbligo di memorizzazione elettronica e trasmissione telematica dei dati relativi a tutti i corrispettivi giornalieri mediante trasmissione degli stessi al Sistema tessera sanitaria, tramite strumenti tecnologici che ne garantiscano l’inalterabilità e la sicurezza (ivi compresi quelli che consentono pagamenti con carte di debito o credito). |
Imposta di bollo sulle fatture elettroniche |
L’art. 17 del DL 124/2019 convertito, modificando l’art 12-novies del DL 34/2019, prevede che in caso di ritardato, omesso o insufficiente versamento dell’imposta di bollo sulle fatture elettroniche trasmesse mediante il Sistema di Interscambio, l’Agenzia delle Entrate comunichi all’interessato, con modalità telematiche:
· l’importo dovuto; · la sanzione amministrativa di cui all’art. 13 del DLgs. 471/97, ridotta a un terzo; · gli interessi calcolati fino all’ultimo giorno del mese antecedente a quello di elaborazione della comunicazione. Qualora il soggetto non proceda al versamento degli importi dovuti entro 30 giorni dalla ricezione della suddetta comunicazione, l’Agenzia delle Entrate provvederà all’iscrizione a ruolo delle somme non versate. Versamenti fino a 1.000,00 euro annui Viene inoltre stabilito che, al fine di semplificare gli adempimenti degli operatori, qualora gli importi dovuti non superino la soglia annua di 1.000,00 euro, il versamento dell’imposta possa essere assolto con cadenza semestrale, entro il 16 giugno e il 16 dicembre di ciascun anno. |
Reverse charge per appalti e subappalti | L’art. 4 co. 3 del DL 124/2019 convertito stabilisce l’introduzione del meccanismo del reverse charge per le prestazioni di servizi effettuate:
· tramite contratti di appalto, subappalto, affidamento a soggetti consorziati o rapporti negoziali comunque denominati, laddove vi sia un prevalente utilizzo di manodopera; · presso le sedi di attività del committente con l’utilizzo di beni strumentali di proprietà di quest’ultimo o ad esso riconducibili in qualunque forma. Esclusioni La nuova disciplina non si applica: · alle prestazioni di servizi relative al settore dell’edilizia (art. 17 co. 6 lett. a) e a-ter) del DPR 633/72) ed alle prestazioni nei confronti della P.A. e di altri enti e società assoggettati a split payment (art. 17-ter del DPR 633/72); · alle agenzie per il lavoro (Capo I del Titolo II del DLgs. 276/2003). |
Efficacia
L’efficacia della nuova fattispecie di reverse charge è subordinata al rilascio, da parte del Consiglio dell’Unione europea, dell’autorizzazione di una specifica misura di deroga alla direttiva 2006/112/CE (art. 4 co. 4 del DL 124/2019 convertito). |
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Lotteria degli scontrini – Rinvio – Premi speciali |
Gli artt. 19 e 20 del DL 124/2019 convertito apportano alcune modifiche alla disciplina della c.d. “lotteria degli scontrini”, con lo scopo di rafforzare l’efficacia della misura e di favorire la diffusione dei pagamenti elettronici.
Quadro normativo La “lotteria degli scontrini” consentirà ai soggetti che effettuano acquisti di beni o servizi, presso esercenti che trasmettono in via telematica i dati dei corrispettivi, di partecipare all’estrazione a sorte di premi messi in palio. La partecipazione alla lotteria è ammessa per le persone fisiche maggiorenni, residenti in Italia, che effettuano acquisti al di fuori dell’esercizio d’impresa, arte o professione. Inoltre, ai fini dell’estrazione: · il cliente dovrà comunicare all’esercente, all’atto dell’acquisto, il proprio codice identificativo (“codice lotteria”); · l’esercente dovrà inviarlo all’Agenzia delle Entrate, unitamente ai dati dell’operazione effettuata (cfr. provv. Agenzia delle Entrate 31.10.2019 n. 739122). Rinvio della lotteria all’1.7.2020 L’art. 20 del DL 124/2019 convertito differisce dall’1.1.2020 all’1.7.2020 l’avvio della lotteria degli scontrini, allineando tale termine di decorrenza all’entrata in vigore, a regime, dei nuovi obblighi di memorizzazione e trasmissione telematica dei corrispettivi. Rinvio al 30.6.2020 dell’adeguamento dei registratori telematici Conseguentemente, è stato differito dal 31.12.2019 al 30.6.2020 il termine entro cui gli esercenti devono adeguare i registratori telematici alle nuove funzioni richieste per l’attuazione della lotteria, vale a dire l’acquisizione del “codice lotteria” dei clienti e la trasmissione dei dati delle operazioni valide per la partecipazione alle estrazioni dei premi (cfr. provv. Agenzia delle Entrate 23.12.2019 n. 1432381). Sistema di segnalazione delle violazioni In sede di conversione in legge, è stata abolita la sanzione amministrativa inizialmente prevista dall’art. 20 del DL 124/2019 per gli esercenti che avessero rifiutato di acquisire il codice identificativo del cliente o che avessero omesso di inviare i dati delle operazioni valide per la lotteria. Il nuovo art. 20 del DL 124/2019 convertito si limita a prevedere un meccanismo di segnalazioni da parte dei clienti. Nello specifico, stabilisce che il cliente ha la facoltà di segnalare sul sito dell’Agenzia delle Entrate, in apposito portale, se l’esercente si è rifiutato di acquisire il codice lotteria. Tale segnalazione sarà poi utilizzata dall’Agenzia delle Entrate e dalla Guardia di finanza nell’ambito delle attività di analisi del rischio di evasione. Esenzione fiscale dei premi Per incoraggiare la partecipazione alla lotteria, viene stabilito che i premi attribuiti nell’ambito della stessa non concorrono a formare il reddito del percipiente, per cui sono esclusi dall’imposizione ai fini IRPEF. Inoltre, sono esenti da qualsiasi ulteriore prelievo erariale. Istituzione di premi speciali in caso di pagamenti elettronici La definizione delle modalità di estrazione, dell’entità dei premi, nonché di ogni altra disposizione attuativa della lotteria è demandata a un provvedimento dell’Agenzia delle Dogane e Monopoli, da adottare d’intesa con l’Agenzia delle Entrate. L’art. 19 del DL 124/2019 convertito prevede che con il medesimo provvedimento: |
· vengano istituiti premi speciali, da attribuire agli acquirenti che effettuano il pagamento mediante mezzi elettronici, mediante estrazioni aggiuntive rispetto a quelle ordinarie;
· vengano istituiti dei premi anche per gli esercenti che certificano le operazioni ex art. 2 co. 1 del DLgs. 127/2015 (ossia mediante registratori telematici o procedura web dell’Agenzia delle Entrate). Va tuttavia rilevato che, in base a quanto indicato nella relazione illustrativa di accompagnamento al decreto, l’attribuzione dei premi per gli esercenti sembra sia comunque subordinata all’utilizzo di mezzi di pagamento elettronici. |
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Semplificazione degli adempimenti IVA | L’avvio graduale dell’obbligo di emissione di fatture elettroniche mediante il Sistema di Interscambio e del processo di memorizzazione elettronica e trasmissione telematica dei corrispettivi ha reso necessario un differimento dell’introduzione della predisposizione, da parte dell’Agenzia delle Entrate, delle bozze dei registri IVA, delle comunicazioni delle liquidazioni periodiche IVA e della dichiarazione annuale IVA.
Conseguentemente, in virtù di quanto disposto dall’art. 16 del DL 124/2019 convertito: · il primo invio delle bozze dei registri IVA e delle comunicazioni delle liquidazioni periodiche IVA avrà luogo a partire dal secondo semestre 2020; · la predisposizione della bozza di dichiarazione annuale IVA verrà messa a disposizione dei soggetti passivi a partire dai dati riferiti al 2021. Scadenze dell’“esterometro” Grazie ad una modifica dell’art. 1 co. 3-bis del DLgs. 127/2015, è stata inoltre prevista una nuova periodicità di trasmissione del c.d. “esterometro”. La trasmissione telematica delle comunicazioni delle operazioni transfrontaliere dovrà infatti essere effettuata trimestralmente, entro la fine del mese successivo al trimestre di riferimento. |
Utilizzo della piattaforma tecnologica AgID |
L’art. 21 co. 1 del DL 124/2019 convertito prevede la possibilità di utilizzare la piattaforma tecnologica per l’interconnessione e l’interoperabilità tra le Pubbliche Amministrazioni e i prestatori di servizi di pagamento abilitati anche per la certificazione fiscale tra soggetti privati, tra cui la fatturazione elettronica e la memorizzazione e trasmissione telematica dei dati dei corrispettivi giornalieri. |
Invio dei corrispettivi mediante strumenti evoluti di incasso |
L’art. 21 co. 1-bis del DL 124/2019 convertito stabilisce, a decorrere dall’1.1.2021, in favore dei commercianti al minuto e dei soggetti assimilati, la possibilità di adempiere agli obblighi di memorizzazione elettronica e trasmissione telematica dei corrispettivi avvalendosi di sistemi evoluti di incasso che consentano l’inalterabilità e la sicurezza dei dati. |
Credito d’imposta su commissioni per pagamenti elettronici |
Per incentivare i mezzi di pagamento elettronici, con l’art. 22 del DL 124/2019 convertito viene previsto il riconoscimento di un credito d’imposta a esercenti attività d’impresa, arti e professioni che hanno ricavi non superiori a 400.000,00 euro.
Il credito d’imposta è pari al 30% delle commissioni addebitate per le transazioni effettuate: · mediante carte di credito, di debito o prepagate emesse da operatori finanziari (banche, poste, ecc.) o con altri mezzi di pagamento elettronici tracciabili; · in relazione a cessioni di beni e prestazioni di servizi rese nei confronti di consumatori finali dall’1.7.2020. |
Agevolazioni fiscali relative ai veicoli elettrici e a motore ibrido utilizzati dagli invalidi | L’art. 53-bis del DL 124/2019 convertito prevede alcune agevolazioni fiscali per i veicoli elettrici e a motore ibrido utilizzati dagli invalidi.
Aliquota IVA del 4% Con la modifica del n. 31 della Tabella A, parte II, allegata al DPR 633/72, l’applicazione dell’aliquota IVA del 4% viene estesa: |
· alle cessioni di motoveicoli e autoveicoli ad alimentazione ibrida ed elettrica effettuate nei confronti dei soggetti di cui all’art. 3 della L. 5.2.92 n. 104, con ridotte o impedite capacità motorie permanenti, oppure dei familiari di cui essi sono fiscalmente a carico;
· alle prestazioni rese ai predetti soggetti dalle officine per adattare tali veicoli, anche non nuovi di fabbrica, compresi i relativi accessori e strumenti necessari per l’adattamento. Detta aliquota IVA si applica anche alle cessioni dei citati autoveicoli a soggetti non vedenti e a soggetti affetti da sordomutismo, nonché ai familiari di cui i predetti soggetti sono fiscalmente a carico. Rientrano nell’ambito di applicazione dell’agevolazione in esame, in particolare, i veicoli: · di cilindrata fino a 2.000 centimetri cubici, se con motore a benzina o ibrido; · di cilindrata fino a 2.800 centimetri cubici, se con motore diesel o ibrido; · di potenza non superiore a 150 kW, se con motore elettrico. Le stesse caratteristiche di potenza sono replicate nell’art. 1 co. 1 della L. 9.4.86 Esenzione dall’imposta di trascrizione Agli atti di natura traslativa o dichiarativa aventi per oggetto i citati veicoli ibridi e a motore elettrico, destinati a portatori di handicap, viene estesa l’esenzione: · dall’imposta erariale di trascrizione; · dall’addizionale provinciale all’imposta erariale di trascrizione; · dall’imposta di registro. |
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Aliquota IVA agevolata su prodotti igienico-sanitari | L’art. 32-ter del DL 124/2019 convertito introduce il n. 1-quinquies nella Tabella A, parte II-bis, allegata al DPR 633/72, al fine di prevedere l’applicazione dell’aliquota IVA del 5%:
· ai prodotti per la protezione dell’igiene femminile compostabili secondo la norma UNI EN 13432:2002 o lavabili; · alle coppette mestruali. Decorrenza La disposizione si applica alle operazioni effettuate a decorrere dall’1.1.2020. |
Omesso versamento dell’imposta unica su concorsi e scommesse – Chiusura dell’esercizio |
L’art. 31 del DL 124/2019 convertito stabilisce che, con provvedimento dell’Agenzia delle Dogane e dei Monopoli, è disposta la chiusura dei punti vendita nei quali si offrono al pubblico scommesse e concorsi pronostici qualora il soggetto che gestisce il punto di vendita risulti debitore dell’imposta unica di cui al DLgs. 23.12.98 n. 504, in base ad una sentenza, anche non definitiva, la cui esecutività non sia sospesa.
La chiusura diventa definitiva con il passaggio in giudicato della sentenza di condanna. La disposizione si applica anche ai punti vendita dei soggetti per conto dei quali l’attività è esercitata, che risultino debitori dell’imposta unica, anche in via solidale con il soggetto gestore del punto vendita. Procedura per la chiusura dell’esercizio Il provvedimento dell’Agenzia delle Dogane e dei Monopoli contiene: · l’invito al pagamento, entro 30 giorni dalla notifica, di quanto dovuto per effetto della sentenza di condanna; · l’intimazione della chiusura se, decorso il periodo previsto, non sia fornita prova dell’avvenuto pagamento. L’Agenzia delle Dogane e dei Monopoli avvisa senza ritardo il competente Comando della Guardia di Finanza per procedere all’esecuzione della chiusura. |
Sanzione per violazione della chiusura dell’esercizio
In caso di violazione della chiusura dell’esercizio, si applica la sanzione amministrativa da 10.000,00 a 30.000,00 euro, oltre alla chiusura dell’esercizio in forma coattiva. Controllo dei pagamenti da parte dei soggetti obbligati L’Agenzia delle Dogane e dei Monopoli procede a diffidare coloro che risultino inadempienti, in tutto o in parte, al versamento di quanto dovuto a titolo di imposta unica, oltre a sanzioni ed interessi, entro 30 giorni. In caso di mancato versamento nei termini, l’Agenzia delle Dogane e dei Monopoli procede all’escussione delle garanzie prestate e il soggetto obbligato è tenuto a reintegrare la garanzia entro 90 giorni dall’escussione, a pena di decadenza della concessione. |
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Piano di risparmio a lungo termine (PIR) – Nuovi requisiti per i PIR costituiti dall’1.1.2020 |
I piani di risparmio a lungo termine (PIR) sono una specifica tipologia di investimento destinato alle persone fisiche residenti previsto dall’art. 1 co. 100 – 114 della L. 232/2016, i cui redditi beneficiano dell’esenzione:· dalle imposte sui redditi derivanti dagli strumenti finanziari e dalla liquidità che concorrono a formare il PIR (sia i redditi di capitale che i redditi diversi);· dall’imposta sulle successioni relativa agli strumenti finanziari che compongono il piano in caso di trasferimento a causa di morte.Novità per i PIR costituiti dall’1.1.2020Per gli investimenti in PIR costituiti a partire dall’1.1.2020, l’art. 13-bis del DL 124/2019 convertito prevede che in ciascun anno di durata del piano, per almeno i due terzi dell’anno stesso, le somme e i valori devono essere investiti per almeno il 70% del valore complessivo in strumenti finanziari, anche non negoziati in mercati regolamentati o nei sistemi multilaterali di negoziazione, emessi e stipulati con imprese residenti nello Stato italiano o in Stati dell’Unione europea (UE) o dello Spazio economico europeo (SEE) con stabile organizzazione in Italia.La predetta quota del 70% deve essere investita: · per almeno il 25% del valore complessivo in strumenti finanziari di imprese diverse da quelle inserite nell’indice FTSE MIB della Borsa italiana o in indici equivalenti di altri mercati regolamentati; · per almeno il 5% del valore complessivo in strumenti finanziari di imprese diverse da quelle inserite nell’indice FTSE MIB e FTSE Mid Cap della Borsa italiana o in indici equivalenti di altri mercati regolamentati. Restano fermi il requisito di detenzione per almeno 5 anni (a tal fine assume rilevanza, in ciascun anno solare, la puntuale data di acquisto degli strumenti e quella di cessione o rimborso) e la possibilità di destinare liberamente il restante 30% della dotazione del PIR, con l’eccezione degli strumenti finanziari emessi da soggetti residenti in Stati o territori diversi da quelli collaborativi. Inoltre, occorre che i PIR non abbiano ad oggetto per più del 10% strumenti finanziari emessi da uno stesso emittente o contratti stipulati con la medesima controparte, ovvero con altra società appartenente al medesimo gruppo, né formare oggetto di rapporti di deposito o conto corrente. PIR costituiti nelle annualità precedenti Per gli investimenti in PIR effettuati prima del 2020, si conferma che resta ferma la precedente disciplina prevista dalla L. 232/2016 e dalla L. 145/2018 (quest’ultima ha definito i requisiti per i PIR costituiti nel 2019). |
Trust – Tassazione dei redditi – Modifiche |
Con l’art. 13 del DL 124/2019 convertito vengono apportate modifiche agli artt. 44 e 45 del TUIR, in materia di tassazione dei redditi corrisposti da trust.
Redditi di capitale in capo ai beneficiari di trust Viene modificato l’art. 44 co. 1 del TUIR, relativo ai redditi di capitale, con riferimento ai redditi imputati da trust. |
In particolare, a seguito delle modifiche, l’art. 44 co. 1 lett. g-sexies) del TUIR dispone che configurano redditi di capitale:
· i redditi imputati al beneficiario di trust ai sensi dell’art. 73 co. 2 del TUIR, anche se non residenti (e con riferimento a questa disposizione, nulla è cambiato); · i redditi corrisposti a residenti italiani da trust e istituti aventi analogo contenuto, stabiliti in Stati e territori che con riferimento al trattamento dei redditi prodotti dal trust si considerano a fiscalità privilegiata ai sensi dell’art. 47-bis del TUIR, anche qualora i percipienti residenti non possano essere considerati beneficiari individuati ai sensi dell’art. 73 del TUIR. Qualificazione dei redditi distribuiti dal trust Si ricorda che i redditi imputati a beneficiari di trust, in base al disposto dell’art. 44 del TUIR, hanno la peculiarità di essere attratti alla categoria dei redditi di capitale quale che sia la loro categoria di reddito originaria. La norma dispone, infatti, che si qualifichino quali redditi di capitale “i redditi imputati al beneficiario di trust ai sensi dell’articolo 73, comma 2, anche se non residenti”. L’Agenzia delle Entrate, nella circ. 27.12.2010 n. 61, aveva interpretato estensivamente la norma, affermando che la qualificazione come redditi di capitale operasse: · non solo per i redditi imputati da trust trasparenti (a beneficiari individuati) residenti o non residenti in Italia; · ma anche da redditi eventualmente e discrezionalmente imputati da trust opachi, in modo da evitare “il conseguimento di indebiti risparmi di imposta che potrebbero essere conseguiti, ad esempio, nell’ipotesi di trust opachi costituiti in giurisdizioni straniere a regime fiscale agevolato. In tal caso, infatti, alla tassazione ridotta in capo al trust corrisponderebbe, comunque, l’imposizione in capo al beneficiario residente secondo il regime del più volte citato articolo 44, comma 1, lettera g-sexies), del TUIR”. Nuova formulazione della norma Ora, la nuova formulazione dell’art. 44 co. 1 lett. g-sexies) del TUIR, intervenendo su questo secondo punto, afferma che possono risultare tassati come redditi di capitale anche i “redditi corrisposti a residenti italiani da trust” opachi esteri (solo se) residenti in Paesi a fiscalità privilegiata ex art. 47-bis del TUIR. Ne dovrebbe derivare che, quindi, i redditi discrezionalmente distribuiti da trust opachi non residenti a soggetti residenti non siano, il linea di principio, imponibili, con la sola eccezione, espressamente individuata dalla nuova norma, dei trust opachi “paradisiaci” (da individuare in base ai parametri di cui all’art. 47-bis del TUIR). In conclusione, il nuovo assetto pare comportare la tassazione quale redditi di capitale: · dei redditi imputati a residenti in Italia da trust trasparenti sia residenti che esteri (in questo campo, nulla cambia rispetto al passato); · dei redditi discrezionalmente “corrisposti” a residenti in Italia da trust opachi residenti in “paradisi fiscali”, mentre non risultano imponibili i redditi distribuiti da trust opachi esteri “non paradisiaci”. Decorrenza La norma non è stata espressamente qualificata come interpretativa, inoltre essa apporta una materiale modifica all’art. 44 del TUIR. Pertanto, si può dubitare della sua possibile portata retroattiva. D’altronde, secondo quanto rilevato dal Direttore dell’Agenzia delle Entrate nell’Audi-zione alla Camera del 6.11.2019 (con riferimento alla disciplina previgente) “stante il riferimento letterale ai «redditi imputati», previsto dall’art. 44, comma 1, lettera g-sexies, le attuali disposizioni fiscali in materia di imposte dirette possono essere |
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riferite sicuramente anche ai «beneficiari individuati» di Trust esteri «trasparenti» mentre è più difficile ricomprendere nell’ambito di applicazione delle stesse i Trust «opachi» esteri (vale a dire Trust i cui eventuali beneficiari possono ricevere il reddito, o parte del reddito, del Trust solo a seguito di una scelta discrezionale operata dal trustee)”.
Ciò significherebbe che, anche per il passato, l’interpretazione fornita dalla circ. 61/2010 sulla tassabilità ad ampio spettro dei redditi di capitale imputati da trust esteri opachi a residenti in Italia non dovrebbe ritenersi ammissibile. Attribuzioni di trust esteri Viene modificato l’art. 45 del TUIR, inserendovi il co. 4-quater, secondo il quale “qualora in relazione alle attribuzioni di trust esteri, nonché di istituti aventi analogo contenuto, a beneficiari residenti in Italia, non sia possibile distinguere tra redditi e patrimonio, l’intero ammontare percepito costituisce reddito”. Secondo quanto indicato dalla Relazione illustrativa al DL 124/2019, la norma intende risolvere le problematiche “inerenti i redditi provenienti da trust «opachi» esteri per i quali spesso i beneficiari italiani si dicono impossibilitati a distinguere la parte delle attribuzioni riferibile al patrimonio del trust rispetto a quelle riferibili al reddito”. Pertanto, la norma intende superare tali difficoltà “interpretative” qualificando normativamente le attribuzioni dubbie quali redditi, passibili, quindi, di imposizione. |
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Deducibilità degli interessi passivi relativi a prestiti per progetti infrastrutturali pubblici a lungo termine (PIPLT) |
L’art. 35 del DL 124/2019 convertito interviene sull’ambito oggettivo di esclusione dai limiti di deducibilità contenuti nell’art. 96 del TUIR degli interessi passivi relativi a prestiti utilizzati per finanziare progetti infrastrutturali pubblici a lungo termine (c.d. “PIPLT”).
Per i soggetti IRES, è prevista l’integrale deducibilità degli interessi passivi (senza monitoraggio del ROL) su prestiti utilizzati per finanziare un PIPLT che presentano tutte le seguenti caratteristiche (art. 96 co. 8 del TUIR): · sono relativi a prestiti, utilizzati per finanziare un progetto infrastrutturale pubblico a lungo termine, che non sono garantiti né da beni appartenenti al gestore del progetto infrastrutturale pubblico diversi da quelli afferenti al progetto infrastrutturale stesso né da soggetti diversi dal gestore del progetto infrastrutturale pubblico (lett. a); · il soggetto gestore del progetto infrastrutturale pubblico a lungo termine è residente, ai fini fiscali, in uno Stato dell’Unione europea (lett. b); · i beni utilizzati per la realizzazione del progetto infrastrutturale pubblico a lungo termine e quelli la cui realizzazione, miglioramento, mantenimento costituiscono oggetto del progetto si trovano in uno Stato dell’Unione europea (lett. c). Garanzia dei soci ed integrale deducibilità degli interessi del PIPLT Attraverso la sostituzione del co. 11 dell’art. 96 del TUIR, il decreto prevede che: · le società di progetto possono dedurre integralmente gli interessi passivi e gli oneri finanziari anche se relativi a prestiti assistiti da garanzie diverse da quelle strettamente previste dalla lett. a) del co. 8 dell’art. 96 del TUIR; · purché tali prestiti siano utilizzati per finanziare progetti infrastrutturali pubblici, non solo rientranti nella Parte V del codice degli appalti, ma anche nelle Parti III e IV dello stesso codice concernenti i contratti di concessione e di partenariato pubblico privato. Con la nuova disposizione, il pegno sulle partecipazioni ed il pegno sui crediti vantati dai soci verso la società non dovrebbero ostacolare l’integrale deducibilità degli interessi relativi al PIPLT delle società di progetto. |
Decorrenza
L’intervento normativo in argomento è in vigore dal 27.10.2019 ed il decreto convertito non presenta una decorrenza specifica in materia di deducibilità degli interessi passivi. Applicando quanto previsto dall’art. 3 co. 1 della L. 27.7.2000 n. 212, le modifiche introdotte dovrebbero applicarsi solo a partire dal periodo d’imposta successivo a quello in corso alla data di entrata in vigore delle disposizioni che le prevedono. |
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Nuovo regime degli impatriati -Decorrenza | Per effetto dell’art. 13-ter del DL 124/2019 convertito, la nuova versione del regime degli impatriati, come modificato dal DL 34/2019, si applica, già dal 2019, ai soggetti che hanno trasferito la residenza fiscale in Italia dal 30.4.2019 (in luogo dell’origi-naria decorrenza prevista per il 2020). |
Cumulo “Tremonti ambientale” e tariffe incentivanti – Procedura di rinuncia |
Mediante l’art. 36 del DL 124/2019 convertito viene stabilito che, in caso di cumulo della c.d. “Tremonti ambientale” con il III, IV o V Conto energia, il mantenimento del diritto a beneficiare delle suddette tariffe incentivanti riconosciute dal GSE alla produzione di energia elettrica è subordinato al pagamento di una somma determinata applicando alla variazione in diminuzione effettuata in dichiarazione relativa alla detassazione per investimenti ambientali l’aliquota d’imposta pro tempore vigente.
I soggetti che intendono avvalersi della citata definizione devono: · presentare un’apposita comunicazione all’Agenzia delle Entrate; · provvedere al pagamento degli importi dovuti entro il termine del 30.6.2020. |
Autotrasportatori – Incentivi per il rinnovo del parco veicolare |
Mediante l’art. 53 del DL 124/2019 convertito vengono stanziate risorse destinate al rinnovo del parco veicolare delle imprese attive sul territorio italiano iscritte al Registro elettronico nazionale e all’Albo nazionale degli autotrasportatori di cose per conto di terzi.
L’entità dei contributi (che sarà meglio definita nel DM attuativo): · sarà compresa tra un minimo di 2.000,00 euro e un massimo di 20.000,00 euro per ciascun veicolo; · sarà differenziata in ragione della massa complessiva a pieno carico del nuovo veicolo e della sua modalità di alimentazione. |
Contrasto alle frodi in materia di accise | L’art. 5 del DL 124/2019 convertito introduce alcune misure finalizzate a contrastare le frodi in materia di accise.
Circolazione in regime sospensivo di prodotti sottoposti ad accisa Con riguardo alla circolazione in regime sospensivo di prodotti sottoposti ad accisa, si prevede che: · la trasmissione della nota di ricevimento dal destinatario nazionale all’Amministrazione finanziaria sia effettuata entro le 24 ore decorrenti dal momento in cui i prodotti sono presi in consegna dal destinatario; · per i trasferimenti mediante automezzi, la presa in consegna si verifichi con lo scarico effettivo dei prodotti dal mezzo di trasporto e con l’iscrizione nella contabilità del destinatario, entro il giorno in cui sono terminate le operazioni di scarico, dei dati accertati relativi alla qualità e quantità dei prodotti scaricati. Destinatari registrati Ai fini del rilascio, della sospensione e della revoca dell’autorizzazione a operare come destinatario registrato, sono introdotti determinati requisiti di onorabilità mutuati dalla disciplina in materia di autorizzazione all’esercizio di un deposito fiscale di prodotti energetici prevista dall’art. 23 co. 6 – 9 del DLgs. 504/95. Si stabilisce, inoltre, l’obbligo del destinatario registrato di sottoporsi a qualsiasi controllo o accertamento anche intesi a verificare l’effettivo ricevimento dei prodotti nonché a riscontrare l’avvenuto pagamento dell’accisa. |
Deposito e circolazione di prodotti energetici assoggettati ad accisa
Si prevede l’obbligo di denuncia dell’esercizio all’ufficio competente dell’Agenzia delle Dogane e Monopoli: · per gli esercenti depositi per uso privato, agricolo e industriale di capacità superiore a 10 metri cubi (prima la soglia era 25 metri cubi); · per gli esercenti apparecchi di distribuzione automatica di carburante per usi privati, agricoli e industriali, collegati a serbatoi la cui capacità globale è superiore a 5 metri cubi (prima la soglia era 10 metri cubi). Per i predetti soggetti i cui depositi o serbatoi non superano, rispettivamente, i 25 o i 10 metri cubi, il registro di carico e scarico è tenuto con modalità semplificate. Gli esercenti impianti e depositi soggetti all’obbligo della denuncia devono soddisfare specifici requisiti di onorabilità per il rilascio dell’autorizzazione. Depositi fiscali di alcole e bevande alcoliche Agli esercenti depositi fiscali di prodotti alcolici sono applicabili i requisiti di onorabilità sopra indicati per i destinatari registrati. |
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Prevenzione delle frodi nel settore dei carburanti |
L’art. 6 del DL 124/2019 convertito prevede alcune modifiche alla disciplina, introdotta dalla legge di bilancio 2018 (art. 1 co. 937 – 943 della L. 205/2017), che subordina l’immissione in consumo dal deposito fiscale o l’estrazione dal deposito di un destinatario registrato di determinati carburanti al versamento dell’IVA, a mezzo modello F24, senza possibilità di compensazione.
Delimitazione delle deroghe all’obbligo di versamento dell’IVA con modello F24 Con riguardo ai prodotti introdotti a seguito di un acquisto intracomunitario, anche qualora il deposito fiscale sia utilizzato come deposito IVA, è stato eliminato il riferimento alla disposizione secondo cui sono effettuate senza pagamento dell’IVA le cessioni dei prodotti che intervengono durante la loro custodia nei depositi. Il campo di applicazione delle seguenti deroghe previste al citato obbligo è delimitato come segue: · per i prodotti introdotti a seguito di acquisto intracomunitario, anche qualora il deposito fiscale sia utilizzato come deposito IVA, occorre rispettare i criteri di affidabilità previsti e prestare idonea garanzia; · per i prodotti di proprietà del gestore del deposito, quest’ultimo deve essere di capacità non inferiore a 3.000 metri cubi (soglia rideterminabile con decreto ministeriale). Tali disposizioni hanno efficacia a decorrere dall’1.1.2020. Impossibilità di avvalersi della dichiarazione di intento Si esclude l’utilizzo della dichiarazione di intento per le cessioni e le importazioni definitive dei predetti carburanti eccetto, a determinate condizioni, per le imprese di trasporto di merci e di persone che acquistano gasolio “commerciale” (art. 24-ter del DLgs. 504/95) ai fini dello svolgimento della loro attività. Messa a disposizione dei dati sulla movimentazione dei prodotti energetici Su richiesta dell’Agenzia delle Dogane e Monopoli nonché della Guardia di Finanza, le società, gli enti e i consorzi concessionari di autostrade e trafori mettono a disposizione i dati rilevati sui transiti degli automezzi che possono essere utilizzati per la movimentazione dei prodotti energetici. |
Contrasto alle frodi nel settore degli idrocarburi e di altri prodotti | L’art. 7 del DL 124/2019 convertito prevede che gli oli lubrificanti di cui ai codici della nomenclatura combinata da 27101981 a 27101999 circolano nel territorio nazionale, nella fase antecedente all’immissione in consumo, con la scorta di un codice amministrativo di riscontro, relativo a ciascun trasferimento dei suddetti prodotti, emesso dal |
Argomento | Descrizione |
segue | sistema informatizzato dell’Agenzia delle Dogane e Monopoli e annotato sulla prescritta documentazione di trasporto.
Ulteriori prodotti interessati La predetta disposizione si applica anche: · alle preparazioni lubrificanti rientranti nel codice della nomenclatura combinata 3403, qualora le stesse siano trasportate sfuse o in contenitori di capacità superiore a 20 litri; · ai prodotti, da individuare con decreto del Ministro dell’Economia e delle Finanze, che possono essere destinati all’impiego come carburanti per motori, combustibili per riscaldamento ovvero come lubrificanti. Richiesta del codice amministrativo di riscontro Il codice amministrativo di riscontro è richiesto telematicamente all’Agenzia delle Dogane e Monopoli non prima delle 48 ore precedenti all’introduzione dei prodotti nel territorio nazionale e comunque almeno 12 ore prima dell’introduzione stessa: · per i prodotti provenienti da un altro Stato membro dell’Unione europea e destinati a essere immessi in consumo nel territorio nazionale, dal soggetto che ne effettua la prima immissione in consumo; · per i prodotti provenienti da un altro Stato membro dell’Unione europea e che non sono destinati a essere immessi in consumo nel territorio nazionale, dal mittente dei prodotti stessi. Decorrenza e modalità di attuazione Le modalità di attuazione della disposizione in esame saranno stabilite con decreto del Ministero dell’Economia e delle Finanze da emanare entro il 25.1.2020. Le disposizioni avranno efficacia a decorrere dal primo giorno del secondo mese successivo alla data di pubblicazione del predetto decreto. |
Disposizioni in materia di accisa sul gasolio commerciale | L’art. 8 del DL 124/2019 convertito stabilisce che, per ciascun trimestre, il rimborso dell’onere conseguente alla maggiore accisa applicata al gasolio commerciale (art. 24-ter del DLgs. 504/95) è riconosciuto entro il limite quantitativo di un litro di gasolio consumato, da ciascun veicolo, per ogni chilometro percorso.DecorrenzaLa disposizione si applica ai consumi di gasolio commerciale effettuati a decorrere dall’1.1.2020. |
Frodi nell’acquisto di veicoli fiscalmente usati |
L’art. 9 del DL 124/2019 convertito prevede che l’Agenzia delle Entrate verifichi la sussistenza delle condizioni di esclusione dall’obbligo di versamento dell’IVA, a mezzo modello F24 ELIDE, per l’immatricolazione o la successiva voltura di autoveicoli, motoveicoli e loro rimorchi oggetto di acquisto intracomunitario a titolo oneroso (art. 1 co. 9-bis del DL 262/2006).
Si introduce la verifica preventiva, dunque, anche per i “privati consumatori” che acquistano mezzi fiscalmente usati in altri Stati membri dell’Unione europea. Gli esiti del controllo operato saranno trasmessi al Dipartimento per i trasporti ai fini dell’immatricolazione del veicolo. Modalità della verifica I termini e le modalità della verifica saranno stabiliti con provvedimento del Direttore dell’Agenzia delle Entrate. |
Estensione del sistema INFOIL | In base a quanto previsto dall’art. 10 del DL 124/2019 convertito, gli esercenti depositi fiscali di prodotti energetici, di cui all’art. 23 co. 3 e 4 del DLgs. 504/95, di capacità non inferiore a 3.000 metri cubi si dovranno dotare, entro il 30.6.2020, di un sistema informatizzato per la gestione della detenzione e della movimentazione della benzina e del gasolio usato come carburante. |
Introduzione del documento amministrativo semplificato telematico |
Modalità di attuazione
I tempi e le modalità di esecuzione saranno stabiliti con determinazione del Direttore dell’Agenzia delle Dogane e Monopoli. L’art. 11 del DL 124/2019 convertito prevede che, entro il 30.6.2020, sia introdotto l’obbligo di utilizzo del sistema informatizzato per la presentazione, esclusivamente in forma telematica, del documento di accompagnamento per la circolazione nel territorio dello Stato della benzina e del gasolio usato come carburante, assoggettati ad accisa. Modalità di attuazione I tempi e le modalità per l’introduzione del predetto obbligo saranno fissati con determinazione del Direttore dell’Agenzia delle Dogane e Monopoli. |
Trasmissione telematica dei quantitativi di energia elettrica e di gas naturale |
Al fine di potenziare gli strumenti per l’identificazione dei fenomeni evasivi nel settore dell’accisa sul gas naturale e sull’energia elettrica, l’art. 12 del DL 124/2019 convertito prevede:
· la presentazione in forma telematica dei dati relativi al prodotto trasportato, da parte dei soggetti che effettuano l’attività di vettoriamento nel settore del gas naturale e dell’energia elettrica; · la trasmissione dei dati relativi ai quantitativi di gas naturale ed energia elettrica fatturati, suddivisi per destinazione d’uso, da parte dei soggetti obbligati previsti agli artt. 26 co. 7 lett. a) e 53 co. 1 lett. a) del DLgs. 504/95. Modalità di attuazione I tempi e le modalità per l’introduzione dei predetti obblighi saranno fissati con determinazione del Direttore dell’Agenzia delle Dogane e Monopoli. |
Convenzioni per la realizzazione di opere di urbanizzazione | Con norma di interpretazione autentica, l’art. 32-quinquies del DL 124/2019 convertito stabilisce che non si considerano corrispettivi rilevanti ai fini IVA i contributi, di cui all’art. 87 co. 9 della L. Provincia Bolzano 17.12.98 n. 13, erogati dalla Provincia per l’esecuzione delle opere di urbanizzazione primaria e di allacciamento da parte degli assegnatari di aree destinate all’edilizia abitativa agevolata in attuazione delle convenzioni di cui all’art. 131 della legge provinciale citata. |
Piattaforme di perforazione offshore | L’art. 32-bis del DL 124/2019 convertito modifica l’art. 2 co. 4 della L. 18.2.97 n. 28, al fine di espungere la cessione di piattaforme di perforazione dalle operazioni assimilate alle cessioni all’esportazione non imponibili IVA (in quanto ricomprese nella nozione di navi destinate all’esercizio di attività commerciali).
Si precisa, inoltre, che le disposizioni contenute nel predetto art. 2 co. 4 della L. 28/97 non si applicano alle piattaforme ancorate a terra con struttura emersa destinata alla coltivazione di idrocarburi o di ausilio alla prospezione, alla ricerca, alla coltivazione e allo sfruttamento di giacimenti di idrocarburi in mare. |
TARI – Determinazione e tariffe |
Gli artt. 57-bis e 58-quinquies del DL 124/2019 convertito modificano la disciplina della TARI e stabiliscono, in particolare:
· la proroga della modalità di misurazione del tributo da parte dei Comuni sulla base di un criterio medio-ordinario e non sull’effettiva quantità di rifiuti prodotti; · la fissazione al 30 aprile del termine di deliberazione delle tariffe per l’anno 2020 (il termine di deliberazione viene quindi scollegato da quello previsto per la deliberazione del bilancio di previsione); · l’accesso alla fornitura del servizio di gestione integrato dei rifiuti urbani e assimilati a condizioni tariffarie agevolate per gli utenti domestici che si trovino in condizioni economico-sociali disagiate (è previsto un bonus sociale anche per le utenze domestiche del servizio rifiuti, secondo criteri simili a quelli già stabiliti per l’energia elettrica, il gas e il servizio idrico); · la modifica della disciplina del metodo normalizzato per la determinazione della TARI al fine di equiparare (in termini di coefficienti da utilizzare per il calcolo della tassa) gli studi professionali alle banche e agli istituti di credito. |
Argomento | Descrizione |
Tasse automobilistiche – Pagamento tramite pagoPA |
L’art. 38-ter del DL 124/2019 convertito stabilisce che, dall’1.1.2020, la tassa automobilistica (c.d “bollo auto”) deve essere pagata esclusivamente attraverso il sistema di pagamenti elettronici “pagoPA” di cui all’art. 5 co. 2 del DLgs. 7.3.2005 n. 82 (Codice dell’amministrazione digitale). |
Tasse automobilistiche – Acquisizione dei dati al Sistema informativo del PRA |
L’art. 51 co. 2-bis – 2-quater del DL 124/2019 convertito stabilisce che al Sistema informativo del Pubblico registro automobilistico (PRA) sono acquisiti anche i dati delle tasse automobilistiche (c.d “bollo auto”), resi disponibili anche all’Agenzia delle Entrate, alle Regioni e alle Province Autonome di Trento e Bolzano.
Questi enti, a loro volta, faranno confluire in modo simultaneo e sistematico i dati dei propri archivi delle tasse automobilistiche nel sistema informativo del PRA. |
Aumenti dell’imposta di soggiorno | L’art. 46 co. 1-bis del DL 124/2019 convertito, modificando l’art. 4 del DLgs. 23/2011, prevede la possibilità di raddoppiare l’imposta di soggiorno nei capoluoghi più turistici.
I Comuni capoluogo di Provincia che hanno avuto presenze turistiche per un numero 20 volte superiore a quello dei residenti, infatti, possono elevare l’imposta di soggiorno fino all’importo massimo di 10,00 euro per notte (in luogo del limite massimo di 5,00 euro per ciascuna persona e per ogni notte di soggiorno). I Comuni che potranno aumentare fino a 10,00 euro l’imposta di soggiorno saranno individuati con un apposito DM. |
Imposta immobiliare sulle piattaforme marine (IMPI) – Istituzione |
L’art. 38 del DL 124/2019 convertito introduce, a decorrere dall’anno 2020, una nuova imposta immobiliare sulle piattaforme marine (IMPI).
Tale imposta è distinta dall’IMU e sostituirà ogni altra imposizione immobiliare locale ordinaria sugli stessi manufatti. Piattaforma marina Per piattaforme marine si intendono quelle con struttura emersa destinata alla coltivazione di idrocarburi e site entro i limiti del mare territoriale come individuato dall’art. 2 del codice della navigazione. Base imponibile La base imponibile è determinata secondo le regole recate dall’art. 5 co. 3 del Aliquota applicabile L’imposta è determinata applicando l’aliquota del 10,6 per mille, di cui: · il 7,6 per mille di competenza dello Stato; · il rimanente 3 per mille di competenza del Comune. Modalità di versamento Per l’anno 2020 l’imposta dovrà essere interamente versata allo Stato in un’unica soluzione entro il 16.12.2020. Per gli anni successivi, i soggetti passivi dovranno effettuare il pagamento del tributo sia allo Stato sia al Comune competente. Accertamento e riscossione Le attività di accertamento e riscossione relative all’IMPI sulle piattaforme marine sono svolte dai Comuni (quindi anche per la parte erariale). Disposizioni applicabili Per quanto non espressamente previsto sono applicabili le disposizioni relative alla deducibilità della “nuova” IMU, la cui disciplina è stata riformata dalla legge di bilancio 2020. |
Estensione delle disposizioni ai rigassificatori
Sono fatte salve le disposizioni contenute nel co. 728 dell’art. 1 della L. 205/2017 riguardanti i manufatti ubicati nel mare territoriale destinati all’esercizio dell’attività di rigassificazione del gas naturale liquefatto. Anche a tali immobili si estendono le disposizioni introdotte per le piattaforme marine. |
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Compartecipazione comunale al gettito accertato |
L’art. 34 del DL 124/2019 convertito, modificando l’art. 1 co. 12-bis del DL 138/2011, proroga di 2 anni, dal 2019 al 2021, l’attribuzione ai Comuni di un contributo nella misura del 100% delle somme riscosse a titolo di accertamento nell’anno precedente a seguito delle segnalazioni qualificate trasmesse dagli stessi enti. |
Eventi sismici della Provincia di Catania – Effettuazione degli adempimenti tributari sospesi |
Mediante l’art. 33 del DL 124/2019 convertito viene prorogato il termine per effettuare i versamenti e gli altri adempimenti tributari sospesi:
· a favore dei soggetti aventi la residenza, ovvero la sede legale o la sede operativa, nei Comuni di Aci Bonaccorsi, Aci Catena, Aci Sant’Antonio, Acireale, Milo, Santa Venerina, Trecastagni, Viagrande e Zafferana Etnea, colpiti dall’evento sismico del 26.12.2018; · scadenti nel periodo dal 26.12.2018 al 30.9.2019. Effettuazione dei versamenti tributari sospesi I versamenti tributari sospesi devono essere effettuati, senza l’applicazione di sanzioni e interessi: · in un’unica soluzione, entro il 16.1.2020; · oppure mediante rateizzazione fino a un massimo di 18 rate mensili di pari importo, da versare entro il 16 di ogni mese, a partire dal 16.1.2020. Effettuazione degli altri adempimenti tributari sospesi Gli adempimenti tributari diversi dai versamenti, non eseguiti per effetto della sospensione, devono essere effettuati entro il mese di gennaio 2020. |
Di seguito si riepilogano le altre principali novità contenute nel DL 26.10.2019 n. 124, conv.
L. 19.12.2019 n. 157.
Argomento | Descrizione | |||
Progressiva riduzione dei limiti all’utilizzo dei contanti |
Con l’art. 18 del DL 124/2019 convertito viene previsto un progressivo abbassamento del limite all’utilizzo del denaro contante verso quota 999,99 euro, dagli attuali 2.999,99 euro. In particolare:
· l’importo limite di 999,99 euro varrà dall’1.1.2022; · dall’1.7.2020 al 31.12.2021, invece, varrà l’importo limite di 1.999,99 euro. Un analogo abbassamento del limite verso quota 999,99 euro è previsto anche per la soglia relativa all’attività di cambiavalute. Conseguenze sulla disciplina sanzionatoria Dal punto di vista sanzionatorio, si ricorda che, fatta salva l’efficacia degli atti, alle violazioni della disciplina in questione si applica la sanzione amministrativa pecuniaria da 3.000,00 a 50.000,00 euro. Per esigenze di coerenza sistematica rispetto alle novità apportate in ordine ai limiti di utilizzo del denaro contante, si prevede che: · per le violazioni commesse e contestate dall’1.7.2020 al 31.12.2021, il minimo edittale sarà pari a 2.000,00 euro (dagli attuali 3.000,00); · per le violazioni commesse e contestate a decorrere dall’1.1.2022, il minimo edittale sarà ulteriormente abbassato a 1.000,00 euro. |
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Per le violazioni che riguardano importi superiori a 250.000,00 euro, la sanzione continua ad essere quintuplicata nel minimo e nel massimo edittali. | ||||
Obbligo di accettare pagamenti tramite carte |
I soggetti che effettuano l’attività di vendita di prodotti e di prestazione di servizi, anche professionali, sono tenuti ad accettare pagamenti effettuati attraverso “carte di pagamento”; tale obbligo non trova applicazione nei casi di oggettiva impossibilità tecnica (sono in ogni caso fatte salve le disposizioni antiriciclaggio del DLgs. 231/2007).
Il DL 124/2019 aveva previsto che, a decorrere dall’1.7.2020, la “mancata accettazione” di pagamenti tramite carte di pagamento, di qualsiasi importo, da parte di soggetti che effettuano l’attività di vendita di prodotti e di prestazione di servizi, anche professionali, sarebbe stata punita con la sanzione amministrativa di 30,00 euro, aumentati del 4% del valore della transazione per la quale fosse stata rifiutata l’accettazione del pagamento. Tale previsione è stata soppressa in sede di conversione in legge. |
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Cassa integrazione guadagni in deroga nelle aree di crisi industriale complessa |
L’art. 58-ter del DL 124/2019 convertito prevede il finanziamento per l’anno 2019 della cassa integrazione guadagni straordinaria in deroga per:
· cessazione di attività (art. 44 del DL 28.9.2018 n. 109); · riorganizzazione o crisi aziendale. Nel primo caso, è possibile autorizzare il trattamento, sino a un massimo di 12 mesi complessivi, previa la stipula di un accordo in sede governativa, per le aziende che cessano l’attività produttiva, ma sussiste almeno una delle seguenti condizioni: · concrete prospettive di cessione e riassorbimento occupazionale; · possibile intervento di reindustrializzazione; · specifici percorsi di politica attiva. Nel secondo caso, l’azienda con rilevanza economica strategica, che presenti rilevanti problematiche occupazionali, può chiedere la proroga della CIGS per una durata funzionale alla causale per cui è stata richiesta. Ai fini della concessione, è necessario: · la stipula di un accordo in sede governativa; · un piano di gestione delle risorse umane volto alla salvaguardia dei livelli occupazionali. |
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Rinegoziazione dei mutui ipotecari per l’acquisto di beni immobili destinati a prima casa e oggetto di procedura esecutiva |
L’art. 41-bis del DL 124/2019 convertito introduce la possibilità per il debitore, a determinate condizioni, ove una banca o una società veicolo, creditrice ipotecaria di primo grado, abbia avviato o sia intervenuta in una procedura esecutiva immobiliare avente ad oggetto la prima casa di abitazione del debitore, di chiedere la rinegoziazione del mutuo in essere ovvero un finanziamento, con surroga nella garanzia ipotecaria esistente, a una banca terza, il cui ricavato deve essere utilizzato per estinguere il mutuo in essere, con assistenza della garanzia del Fondo di garanzia prima casa e con il beneficio dell’esdebitazione per il debito residuo.
Disposizioni attuative Con decreto interministeriale saranno stabilite le ulteriori modalità applicative della nuova disciplina. |
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4 Novità in materia di diritto penale tributario
Di seguito si riepilogano le novità in materia di diritto penale tributario contenute nel DL 26.10.2019
n. 124, conv. L. 19.12.2019 n. 157.
Argomento | Descrizione | |||
Premessa – Entrata in vigore |
Sono previste numerose e rilevanti novità in materia di diritto penale tributario di cui al DLgs. 74/2000 (recante disciplina dei reati in materia di imposte sui redditi e di IVA) attraverso:
· interventi su talune sanzioni (aumentate) e soglie di punibilità (ridotte); · l’estensione alle sole fattispecie penali tributarie “fraudolente” (artt. 2, 3, 8 e 11 del DLgs. 74/2000) della c.d. “confisca per sproporzione” o “allargata”; · la configurazione delle sole fattispecie più gravi (artt. 2, 3, 8, 10 e 11 del DLgs. 74/2000) quali reati presupposto della responsabilità amministrativa degli enti ex DLgs. 231/2001; · l’estensione della causa di non punibilità di cui all’art. 13 co. 2 del DLgs. 74/2000 anche alle fattispecie di cui agli artt. 2 e 3 del DLgs. 74/2000. Entrata in vigore Tali novità hanno efficacia dal 24.12.2019 (data di pubblicazione sulla Gazzetta Ufficiale della legge di conversione del DL 124/2019). Confisca “per sproporzione” o “allargata” La confisca “per sproporzione” o “allargata” è disciplinata dall’art. 240-bis c.p., ai sensi del quale, nei casi di condanna o di patteggiamento per una serie specifica di reati, “è sempre disposta la confisca del denaro, dei beni o delle altre utilità di cui il condannato non può giustificare la provenienza e di cui, anche per interposta persona fisica o giuridica, risulta essere titolare o avere la disponibilità a qualsiasi titolo in valore sproporzionato al proprio reddito, dichiarato ai fini delle imposte sul reddito, o alla propria attività economica. In ogni caso il condannato non può giustificare la legittima provenienza dei beni sul presupposto che il denaro utilizzato per acquistarli sia provento o reimpiego dell’evasione fiscale, salvo che l’obbligazione tributaria sia stata estinta mediante adempimento nelle forme di legge. (…) quando non è possibile procedere alla confisca del denaro, dei beni e delle altre utilità di cui allo stesso comma, il giudice ordina la confisca di altre somme di denaro, di beni e altre utilità di legittima provenienza per un valore equivalente, delle quali il reo ha la disponibilità, anche per interposta persona”. È da osservare che la c.d. confisca “per sproporzione” o “allargata” sarebbe, secondo quanto precisato dalla giurisprudenza, una misura di sicurezza patrimoniale. Di conseguenza, in base a quanto disposto dall’art. 200 c.p., la stessa è regolata dalla legge in vigore al tempo della sua applicazione, con l’effetto che la misura può essere disposta anche nei casi in cui la condanna sia pronunciata per un reato commesso in epoca anteriore all’entrata in vigore della previsione di relativa applicazione. Onde evitare tale effetto, in sede di conversione in legge è stato precisato che la confisca “per sproporzione” si applicherà esclusivamente ai reati tributari contemplati commessi successivamente al 25.12.2019 (data di entrata in vigore della legge di conversione del DL 124/2019). |
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Dichiarazione fraudolenta mediante uso di documenti falsi |
In relazione alla fattispecie di cui all’art. 2 del DLgs. 74/2000 (dichiarazione fraudolenta mediante uso di fatture o altri documenti per operazioni inesistenti) le novità riguardano:
· la pena comminata; · la previsione di un’ipotesi attenuata; · l’applicabilità della c.d. confisca “per sproporzione” o “allargata”; · la possibilità di conseguire la non punibilità a fronte di una fattispecie già integrata; · l’introduzione della responsabilità amministrativa degli enti nel cui interesse o vantaggio si è agito, ex DLgs. 231/2001. |
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Pena comminata
In via generale, è previsto un aumento della pena che passa dalla reclusione da un anno e 6 mesi a 6 anni alla reclusione da 4 a 8 anni. Ipotesi attenuata La reclusione da un anno e 6 mesi a 6 anni resta applicabile nei soli casi in cui l’ammontare degli elementi passivi fittizi indicati in dichiarazione sia inferiore a 100.000,00 euro. Confisca “per sproporzione” o “allargata” Nei casi di condanna o di patteggiamento per il delitto in questione commesso successivamente al 25.12.2019 (data di entrata in vigore della legge di conversione del DL 124/2019) si applica la c.d. confisca “per sproporzione” o “allargata” quando l’ammontare degli elementi passivi fittizi risulti superiore a 200.000,00 euro. Non punibilità Anche il reato di dichiarazione fraudolenta mediante utilizzo di fatture o altri documenti per operazioni inesistenti diviene non punibile se i debiti tributari, comprese sanzioni e interessi, vengono estinti mediante integrale pagamento degli importi dovuti, a seguito del ravvedimento operoso, entro il termine di presentazione della dichiarazione relativa al periodo d’imposta successivo, sempreché il ravvedimento sia intervenuto prima che l’autore del reato abbia avuto formale conoscenza di accessi, ispezioni, verifiche o dell’inizio di qualunque attività di accertamento amministrativo o di procedimenti penali. Responsabilità ex DLgs. 231/2001 La fattispecie di dichiarazione fraudolenta mediante uso di fatture o altri documenti per operazioni inesistenti diviene, inoltre, “reato presupposto” della responsabilità degli enti ex DLgs. 231/2001. In caso di integrazione del reato a vantaggio o nell’interesse dell’ente per il quale è presentata la dichiarazione fraudolenta, quindi, l’ente stesso è punito con una sanzione pecuniaria da 100 a 500 quote, nel caso di integrazione dell’ipotesi più grave, ovvero quando l’ammontare degli elementi passivi fittizi è pari o superiore a 100.000,00 euro, o con una sanzione pecuniaria da 100 a 400 quote, nel caso di integrazione della fattispecie attenuata, ovvero quando l’ammontare degli elementi passivi fittizi è inferiore a 100.000,00 euro. Si è anche precisato che: · se, in seguito alla commissione del delitto in questione, l’ente ha conseguito un profitto di rilevante entità, la sanzione pecuniaria è aumentata di un terzo; · si applicano le sanzioni interdittive di cui all’art. 9 co. 2 lett. c), d) ed e) del |
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Dichiarazione fraudolenta mediante altri artifici |
In relazione alla fattispecie di cui all’art. 3 del DLgs. 74/2000 (dichiarazione fraudolenta mediante altri artifici) le novità riguardano:
· la pena comminata; · la possibilità di conseguire la non punibilità a fronte di una fattispecie già integrata; · l’applicabilità della c.d. confisca “per sproporzione” o “allargata”; · l’introduzione della responsabilità amministrativa degli enti nel cui interesse o vantaggio si è agito, ex DLgs. 231/2001. |
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Argomento | Descrizione | |||
Pena comminata
È previsto un aumento della pena che passa dalla reclusione da un anno e 6 mesi a 6 anni alla reclusione da 3 a 8 anni. Non punibilità Anche il reato di dichiarazione fraudolenta mediante altri artifici diviene non punibile se i debiti tributari, comprese sanzioni e interessi, vengono estinti mediante integrale pagamento degli importi dovuti, a seguito del ravvedimento operoso, entro il termine di presentazione della dichiarazione relativa al periodo d’imposta successivo, sempreché il ravvedimento sia intervenuto prima che l’autore del reato abbia avuto formale conoscenza di accessi, ispezioni, verifiche o dell’inizio di qualunque attività di accertamento amministrativo o di procedimenti penali. Confisca “per sproporzione” o “allargata” Nei casi di condanna o di patteggiamento per il delitto in questione commesso successivamente al 25.12.2019 (data di entrata in vigore della legge di conversione del DL 124/2019) si applica la c.d. confisca “per sproporzione” o “allargata” quando l’imposta evasa è superiore a 100.000,00 euro. Responsabilità ex DLgs. 231/2001 La fattispecie di dichiarazione fraudolenta mediante altri artifici diviene, inoltre, “reato presupposto” della responsabilità degli enti ex DLgs. 231/2001. In caso di integrazione del reato a vantaggio o nell’interesse dell’ente per il quale è presentata la dichiarazione fraudolenta, quindi, l’ente stesso è punito con una sanzione pecuniaria da 100 a 500 quote. Si è anche precisato che: · se, in seguito alla commissione del delitto in questione, l’ente ha conseguito un profitto di rilevante entità, la sanzione pecuniaria è aumentata di un terzo; · si applicano le sanzioni interdittive di cui all’art. 9 co. 2 lett. c), d) ed e) del |
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Dichiarazione infedele |
In relazione alla fattispecie di cui all’art. 4 del DLgs. 74/2000 (dichiarazione infedele) le novità riguardano:
· la pena comminata; · le soglie di punibilità; · la non punibilità correlata alle valutazioni. Pena comminata È previsto un aumento della pena che passa dalla reclusione da uno a 3 anni alla reclusione da 2 a 4 anni e 6 mesi. Soglie di punibilità Per l’integrazione della fattispecie sarà, congiuntamente, necessario che: · l’imposta evasa sia superiore, con riferimento a taluna delle singole imposte, a 100.000,00 euro (e non più a 150.000,00 euro); · l’ammontare complessivo degli elementi attivi sottratti all’imposizione, anche mediante indicazione di elementi passivi inesistenti, sia superiore al 10% dell’ammontare complessivo degli elementi attivi indicati in dichiarazione, o, comunque, sia superiore a due milioni di euro (e non più a tre milioni di euro). Non punibilità correlata alle valutazioni Nella previsione secondo la quale “non danno luogo a fatti punibili le valutazioni che «singolarmente» considerate, differiscono in misura inferiore al 10 per cento da quel |
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le corrette. Degli importi compresi in tale percentuale non si tiene conto nella verifica del superamento delle soglie di punibilità previste dal comma 1, lettere a) e b)”, l’avverbio “singolarmente” è sostituito dall’avverbio “complessivamente”. | ||||
Omessa dichiarazione |
In relazione alle fattispecie di cui all’art. 5 del DLgs. 74/2000 (omessa dichiarazione) le novità riguardano la sola pena comminata.
In particolare, sia in relazione all’omessa dichiarazione ai fini delle imposte dirette e dell’IVA, che con riguardo all’omessa dichiarazione di sostituto d’imposta, è previsto un aumento della pena che passa dalla reclusione da un anno e 6 mesi a 4 anni alla reclusione da 2 a 5 anni. |
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Emissione di fatture false |
In relazione alla fattispecie di cui all’art. 8 del DLgs. 74/2000 (emissione di fatture o altri documenti per operazioni inesistenti), in corrispondenza con quanto stabilito in relazione alla fattispecie di dichiarazione fraudolenta mediante utilizzo di documenti falsi, le novità riguardano:
· la pena comminata; · la previsione di un’ipotesi attenuata; · l’applicabilità della c.d. confisca “per sproporzione” o “allargata”; · l’introduzione della responsabilità amministrativa degli enti nel cui interesse o vantaggio si è agito, ex DLgs. 231/2001. Pena comminata In via generale, è previsto un aumento della pena che passa dalla reclusione da un anno e 6 mesi a 6 anni alla reclusione da 4 a 8 anni. Ipotesi attenuata La reclusione da un anno e 6 mesi a 6 anni resta applicabile nei soli casi in cui l’ammontare dell’importo non rispondente al vero indicato nelle fatture o nei documenti, per periodo d’imposta, sia inferiore a 100.000,00 euro. Confisca “per sproporzione” o “allargata” Nei casi di condanna o di patteggiamento per il delitto in questione commesso successivamente al 25.12.2019 (data di entrata in vigore della legge di conversione del DL 124/2019) si applica la c.d. confisca “per sproporzione” o “allargata” quando l’importo non rispondente al vero indicato nelle fatture o nei documenti sia superiore a 200.000,00 euro. Responsabilità ex DLgs. 231/2001 La fattispecie di emissione di fatture o altri documenti per operazioni inesistenti diviene, inoltre, “reato presupposto” della responsabilità degli enti ex DLgs. 231/2001. In caso di integrazione del reato a vantaggio o nell’interesse dell’ente, questo è punito con una sanzione pecuniaria da 100 a 500 quote, nel caso di integrazione dell’ipotesi più grave, ovvero quando l’importo non rispondente al vero indicato nelle fatture o nei documenti, per periodo d’imposta, sia pari o superiore a 100.000,00 euro, o con una sanzione pecuniaria da 100 a 400 quote, nel caso di integrazione della fattispecie attenuata, ovvero quando l’importo non rispondente al vero indicato nelle fatture o nei documenti, per periodo d’imposta, sia inferiore a 100.000,00 euro. Si è anche precisato che: · se, in seguito alla commissione del delitto in questione, l’ente ha conseguito un profitto di rilevante entità, la sanzione pecuniaria è aumentata di un terzo; · si applicano le sanzioni interdittive di cui all’art. 9 co. 2 lett. c), d) ed e) del |
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Occultamento o distruzione di documenti contabili |
In relazione alla fattispecie di cui all’art. 10 del DLgs. 74/2000 (occultamento o distruzione di documenti contabili) le novità riguardano:
· la pena comminata; · l’introduzione della responsabilità amministrativa degli enti nel cui interesse o vantaggio si è agito, ex DLgs. 231/2001. Pena comminata È previsto un aumento della pena che passa dalla reclusione da un anno e 6 mesi a 6 anni alla reclusione da 3 a 7 anni. Responsabilità ex DLgs. 231/2001 La fattispecie di occultamento o distruzione di documenti contabili diviene, inoltre, “reato presupposto” della responsabilità degli enti ex DLgs. 231/2001. In caso di integrazione del reato a vantaggio o nell’interesse dell’ente, quindi, l’ente stesso è punito con una sanzione pecuniaria da 100 a 400 quote. Si è anche precisato che: · se, in seguito alla commissione del delitto in questione, l’ente ha conseguito un profitto di rilevante entità, la sanzione pecuniaria è aumentata di un terzo; · si applicano le sanzioni interdittive di cui all’art. 9 co. 2 lett. c), d) ed e) del |
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Sottrazione fraudolenta al pagamento delle imposte |
In relazione alla fattispecie di cui all’art. 11 co. 1 del DLgs. 74/2000 (sottrazione fraudolenta al pagamento delle imposte) le novità riguardano:
· l’applicabilità della c.d. “confisca per sproporzione” o “allargata”; · l’introduzione della responsabilità amministrativa degli enti nel cui interesse o vantaggio si è agito, ex DLgs. 231/2001. Confisca “per sproporzione” o “allargata” Nei casi di condanna o di patteggiamento per il delitto in questione commesso successivamente al 25.12.2019 (data di entrata in vigore della legge di conversione del DL 124/2019) si applica la c.d. confisca “per sproporzione” o “allargata” quando l’ammontare delle imposte, delle sanzioni e degli interessi sia superiore a 100.000,00 euro. Responsabilità ex DLgs. 231/2001 La fattispecie di sottrazione fraudolenta al pagamento delle imposte diviene, inoltre, “reato presupposto” della responsabilità degli enti ex DLgs. 231/2001. In caso di integrazione del reato a vantaggio o nell’interesse dell’ente, quindi, l’ente stesso è punito con una sanzione pecuniaria da 100 a 400 quote. Si è anche precisato che: · se, in seguito alla commissione del delitto in questione, l’ente ha conseguito un profitto di rilevante entità, la sanzione pecuniaria è aumentata di un terzo; · si applicano le sanzioni interdittive di cui all’art. 9 co. 2 lett. c), d) ed e) del |
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Falso in transazione fiscale |
In relazione alla fattispecie di cui all’art. 11 co. 2 del DLgs. 74/2000 (falso in transazione fiscale) la novità riguarda la sola applicabilità della c.d. confisca “per sproporzione” o “allargata”. | |||
Nei casi di condanna o di patteggiamento per il delitto in questione commesso successivamente al 25.12.2019 (data di entrata in vigore della legge di conversione del DL 124/2019), infatti, si applica la c.d. confisca “per sproporzione” o “allargata” quando l’ammontare degli elementi attivi inferiori a quelli effettivi o degli elementi passivi fittizi sia superiore a 200.000,00 euro. | ||||
Confisca in relazione alle imposte sulla produzione e sui consumi |
Nell’ambito delle frodi in materia di accise, nel caso di condanna o di patteggiamento per uno dei delitti previsti dal Titolo I Capo IV del DLgs. 504/95, è sempre ordinata la confisca dei beni che ne costituiscono il profitto o il prezzo, salvo che appartengano a persona estranea al reato, ovvero, quando essa non è possibile, la confisca di beni, di cui il reo ha la disponibilità, per un valore corrispondente a tale prezzo o profitto.
La confisca di cui sopra – che, quindi, diviene obbligatoria anche per il profitto del reato oltre ad essere praticabile anche per equivalente – non opera per la parte che il contribuente si impegna a versare all’Erario anche in presenza di sequestro. In caso di mancato versamento, previa diffida al contribuente inadempiente, la confisca è sempre disposta. Entrata in vigore Tale novità, in assenza di differenti indicazioni, è in vigore dal 27.10.2019. Trattandosi di misure aventi natura sanzionatoria, peraltro, dovrebbero trovare applicazione, negli aspetti di novità, ai soli reati perpetrati a decorrere dalla suddetta data, salva la disciplina di successione di leggi penali prevista dall’ultimo comma dell’art. 2 c.p. |
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Almanya’nın en iyi medyumu haluk hoca sayesinde sizlerde güven içerisinde çalışmalar yaptırabilirsiniz, 40 yıllık uzmanlık ve tecrübesi ile sizlere en iyi medyumluk hizmeti sunuyoruz.
Almanya’nın en çok tercih edilen medyumu haluk yıldız hoca olarak bilinmektedir, 40 yıllık tecrübesi ile sizlere en iyi bağlama işlemini yapan ilk medyum hocadır.
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Almanya Hamburg medyum en çok tercih edilen medyumu haluk yıldız hoca olarak bilinmektedir, 40 yıllık tecrübesi ile sizlere en iyi bağlama işlemini yapan ilk medyum hocadır.
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Merhaba Ben Haluk Hoca, Aslen Irak Asıllı Arap Hüseyin Efendinin Torunuyum. Yaklaşık İse 40 Yıldır Havas Ve Hüddam İlmi Üzerinde Sizlere 100 Sonuç Veren Garantili Çalışmalar Hazırlamaktayım, 1964 Yılında Irak’ın Basra Şehrinde Doğdum, Dedem Arap Hüseyin Efendiden El Aldım Ve Sizlere 1990 lı Yıllardan Bu Yana Medyum Hocalık Konularında Hizmet Veriyorum, 100 Sonuç Vermiş Olduğum Çalışmalar İse, Giden Eşleri Sevgilileri Geri Getirme, Aşk Bağlama, Aşık Etme, Kısmet Açma, Büyü Bozma Konularında Garantili Sonuçlar Veriyorum, Başta Almanya Fransa Hollanda Olmak Üzere Dünyanın Neresinde Olursanız Olun Hiç Çekinmeden Benimle İletişim Kurabilirsiniz.
Almanya’nın en iyi güvenilir medyumunun tüm sosyal medya hesaplarını sizlere paylaşıyoruz, güvenin ve kalitelin tek adresi olan medyum haluk hoca 40 yıllık uzmanlığı ile sizlerle.
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Almanya’nın en iyi güvenilir medyumunun tüm sosyal medya hesaplarını sizlere paylaşıyoruz, güvenin ve kalitelin tek adresi olan medyum haluk hoca 40 yıllık uzmanlığı ile sizlerle.
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Dünyaca ünlü medyum haluk hocayı sizlere tanıtıyoruz anlatıyoruz, Avrupanın ilk ve tek medyum hocası 40 yıllık uzmanlık ve tecrübesi ile sizlerle.
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Dünyaca ünlü medyum haluk hocayı sizlere tanıtıyoruz anlatıyoruz, Avrupanın ilk ve tek medyum hocası 40 yıllık uzmanlık ve tecrübesi ile sizlerle.
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Belçika’nın en iyi medyumu medyum haluk hoca ile sizlerde en iyi çalışmalara yakınsınız, hemen arayın farkı görün.
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Belçika’nın en iyi medyumu medyum haluk hoca ile sizlerde en iyi çalışmalara yakınsınız, hemen arayın farkı görün.
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Medyum haluk hoca avrupanın en güvenilir medyum hocasıdır, sizlerinde bilgiği gibi en iyi medyumu bulmak zordur, biz sizlere geldik.
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Ünlülerin tercih ettiği medyum hocamıza dilediğiniz zaman ulaşabilirsiniz, medyum haluk hocamız sizlerin daimi yanında olacaktır.
Birincisi güvenilir medyum hocaları bulmak olacaktır, ikinci seçenek ise en iyi medyumları bulmak olacaktır, siz hangisini seçerdiniz.
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Sizler için en iyi medyum hoca tanıtımı yapıyoruz, Avrupanın en ünlü medyum hocası haluk yıldız hoca sizlerin güvenini hızla kazanmaya devam ediyor.
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Dünyaca ünlü medyum haluk hoca, 40 yıllık uzmanlık ve tecrübesi ile sizlere en iyi hizmetleri vermeye devam ediyor, Aşk büyüsü bağlama büyüsü giden sevigiliyi geri getirme.
Dünyaca ünlü medyum haluk hoca, 40 yıllık uzmanlık ve tecrübesi ile sizlere en iyi hizmetleri vermeye devam ediyor, Aşk büyüsü bağlama büyüsü giden sevigiliyi geri getirme.
Dünyaca ünlü medyum haluk hoca, 40 yıllık uzmanlık ve tecrübesi ile sizlere en iyi hizmetleri vermeye devam ediyor, Aşk büyüsü bağlama büyüsü giden sevigiliyi geri getirme.
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Medyum sitesi medyum hocamızın web sayfasını sizlere en iyi şekilde tanıtıyoruz, güzel yorumlarınız içinde teşekkkür ediyoruz.
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Ünlülerin tercihi medyum haluk hoca sizlerle, en iyi medyum sitemizi ziyaret ediniz.
Ünlülerin tercihi medyum haluk hoca sizlerle, en iyi medyum sitemizi ziyaret ediniz.
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Ünlülerin tercihi medyum haluk hoca sizlerle, en iyi medyum sitemizi ziyaret ediniz.
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If you are heading inside to make another round of beverages or check on the next program for your supper event, be sure to put somebody in charge of watching on the fire. Despite a screen to capture errant sparks as well as embers, something could slide via and also start a fire beyond the firebox. Dead fallen leaves, twigs, branches, dead lawn and also other yard particles can position a serious fire danger if not cleared away from fire attributes. See to it there goes to the very least a 10-foot area free from all lawn waste on all sides of your patio fireplace.
This rusting hulk of a grill is offered on the internet, for an “upscale way of life”. Numerous naive individuals will be guided to ‘need one’, without thought to the environmental damages they will certainly spew around themselves. In underdeveloped countries it is recognized that outside fires substantially reduce the average human lifetime. It appears foolish to consider timber fires as a lifestyle enhancement.
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One of the most common factors people like to have an outdoor fire place is that it supplies a natural prime focus, establishes a specific state of mind and adds some warmth chilly evenings. But there are lots of other reasons you might wish to go with a fireplace over a fire pit or fire table. Typically one of the most remarkable and also long-term outdoor fireplace systems, typically made up of brick or rock, have actually developed from scratch – however those days are long gone.
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With sustainability in mind, the market development rate is expected to be around 1.8 x by 2032. Germany’s market is anticipated to reach US$ 178.9 million, and a CAGR of 3% by 2032. Below is why having an eco-friendly printer is essential now even more than ever before as told by InkJetSuperStore.
Moreover, if cleansing anilox rolls is an obstacle, maintaining the depth-to-opening ratio at much less than 40 percent will make rolls easier to preserve. One major factor that will affect the ink transfer from the anilox cells is the cell form and etching geometry. In order to ensure a consistent ink film density, the anilox spec need to be within a depth-to-opening proportion of approximately 30 percent. This will make certain a great, reliable ink launch from the anilox cells to home plate. Sonia Arcos, technical sales director at Cheshire Anilox Modern technology, highlights 4 steps tag converters can take to boost print top quality.
Various Software Settings To Boost Your Print Speed
I really hope these 3D printing pointers and methods covered in this short article helped you boost print quality of your 3D printer. I would like to hear from you if this post assisted you, and do not be reluctant of showing off your print results in the comment section. Air conditioning demands are directly connected to the filament extrusion temperature, print rate and model dimension. As an example, you need extra cooling if your published version is tiny, and layers do not have adequate time to cool correctly before the 2nd layer is printed over. You may decide to print more slowly for a variety of factors, such as printing a single small object or a part that’s been challenging to print in the past. Most thermoplastic products publish perfectly well at temperature levels lower than you ‘d normally utilize.
Additionally, these materials are usually much more sturdy and durable than various other types of printer products, which helps to reduce the need for frequent substitute of components. Choosing this inlay will certainly assist in saving resources throughout manufacturing, such as conserving water, power, and greenhouse gasses. This supply is designed with the high-sensitivity UCODE 9 chipset to permit high read ranges of approximately 19m. Throughout the years, Zebra Technologies has actually established printing materials to offer even more green printing services. In order to hone in on the advantages of Post-Consumer Recycled Material, Zebra created the Z-Perform 2000D Eco Liner, which is composed of 90% PCR products. In addition, Zebra created the Z-PolyPro 4000D-Eco tag, which has been formulated to be able to recycle with PE flexible envelope while maintaining its high efficiency.
Are Thermal Printers Eco Friendly?
Additionally, to sustainability, publishing modern technology is also driving innovation in printing consumables. 3D printing modern technology is changing the means we think about printing, permitting the production of three-dimensional objects making use of an electronic documents and a 3D printer. An additional way to exercise green-friendly printing is to use vegetable-based ink such as soy ink. Aside from utilizing green printers and buying remanufactured ink cartridges, business must explore using recyclable paper and green inks.
Utilizing 3d printing solutions, suppliers can cut costs by producing little run items that would have been expensive to make by conventional methods. They only need to send out the layout data from their computer-aided layout software program to publish the product at a very little cost. 3d printing technology is a new & sought-after technical development that uses an additive production process to produce three-dimensional solid objects completely colour.
Using environment-friendly printing practices is a wonderful means to integrate environmentally friendly printers, paper, and ink for an eco-friendly and lasting work environment, that also improves effectiveness and reduces operation costs.
On top of that, lots of multifunction printers come with software application that simplifies printing and scanning procedures, making them also much easier to use. They make use of much less power than traditional large-format printers, lowering energy expenses and environmental effect. Furthermore, they create less waste than standard printing methods, as they do not require printing plates or various other products that produce waste. Furthermore, multifunction printers are created for high-volume printing, allowing organizations to publish large-format papers quickly and effectively. This can assist companies satisfy limited deadlines and enhance operations. It’s a popular fact that electronic printing is very quickly, and most large format printers utilize the exact same production procedures that electronic printers utilize.
Updating your printer motorists and software application to boost print high quality ends up being much more advantageous when you have a slightly older printer. Yes, your printer is older, yet you may end up with more recent software because of the upgrade. A lot of the printers produce the very best quality when versions are published gradually, however there are diminishing returns publishing slower than ~ 25-30 mm/s.
Upgrade Your Paper Top Quality
By doing this, you are executing the change with the exact same conditions as when printing. A lot of the moment, the X gantry is skewed on printers which have a single Z screw but you can also have comparable issues with double Z printers. Our packaging and print experts prepare to get more information regarding your brand and ‘unpack’ your demands. Making use of personalized techniques and press results can often develop amazing impacts that would or else need specialty substrates.
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