Diritto tributario e societario

DECRETO FISCALE COLLEGATO ALLA LEGGE DI BILANCIO 2019 -Novità introdotte in sede di conversione nella L. 17.12.2018 n. 136

Con il DL 23.10.2018 n. 119, pubblicato sulla G.U. 23.10.2018 n. 247, è stato emanato il c.d. “decreto fiscale collegato alla legge di bilancio 2019”.

Il DL 23.10.2018 n. 119 è stato convertito nella L. 17.12.2018 n. 136, pubblicata sulla G.U. 18.12.2018 n. 293, preve­dendo nume­rose novità rispetto al testo originario.

Il DL 119/2018 è entrato in vigore il 24.10.2018, mentre la L. 136/2018 è entrata in vigore il 19.12.2018. Tuttavia, per numerose disposizioni sono previste specifiche decorrenze.

Di seguito si analizzano le altre principali novità introdotte in sede di conversione del DL 119/2018.

 

Novità in materia di rottamazione dei ruoli

Viene confermata la rottamazione dei ruoli che, per i carichi affidati agli Agenti della riscossione dall’1.1.2000 al 31.12.2017, consente di fruire dello stralcio delle sanzioni tributarie/contributive e degli interessi di mora.

 

La relativa domanda andrà presentata entro il 30.4.2019.

 

I versamenti possono avvenire in unica soluzione oppure in forma rateale.

 

Gli importi dovuti, che verranno comunicati dall’Agente della riscossione entro il 30.6.2019, possono essere pagati:

  • in 18 rate, le prime due con scadenza 31.7.2019 e 30.11.2019 in misura pari al 10% del debito ciascuna; le successive, di pari importo, scadono al 28.2, 31.5, 31.7 e 30.11 degli anni dal 2020 al 2023;
  • oppure in unica soluzione entro il 31.7.2019.

 

I soggetti che, entro il 7.12.2018, hanno eseguito, in unica soluzione, i pagamenti delle rate da rot­tamazione scadute a luglio, settembre e ottobre 2018 mantengono i benefici della rottamazione, inclusa la ridilazione del debito residuo, senza necessità di inviare alcuna domanda.

Questi debitori possono pagare il debito residuo in 10 rate di pari importo, con scadenza al 31.7 e 30.11 degli anni dal 2019 al 2023.

 

Si prevede inoltre che il tardivo pagamento delle rate, contenuto nei cinque giorni, non ha effetti pregiudizievoli.

 

novità in materia di definizione delle liti pendenti

La definizione delle liti pendenti, che deve avvenire, mediante la presentazione del relativo modello e il pagamento delle somme o della prima rata, entro il 31.5.2019, comporta benefici che dipendono dall’andamento del processo.

 

Sono definibili le liti in cui è controparte l’Agenzia delle Entrate rientranti nella giurisdizione tributaria.

 

Per poter definire, è necessario che, al momento di presentazione della domanda, non si sia ancora formato il giudicato, e che al 24.10.2018 sia già stato notificato alla controparte il ricorso introduttivo di primo grado.

 

I benefici sono i seguenti:

  • se la causa pende in primo grado e non c’è ancora stata la sentenza, spetta lo stralcio di sanzioni e interessi oltre allo sconto del 10% sull’imposta;
  • se il contribuente, in primo e/o in secondo grado, è risultato soccombente al 24.10.2018, spetta il solo stralcio di sanzioni e interessi;
  • se il contribuente, al 24.10.2018, ha vinto in primo grado, spetta lo stralcio di sanzioni e interessi oltre allo sconto del 60% sull’imposta;
  • se il contribuente, al 24.10.2018, ha vinto in secondo grado, spetta lo stralcio di sanzioni e interessi oltre allo sconto dell’85% sull’imposta;
  • se, al 19.12.2018, il processo pende in Cassazione e il contribuente è risultato vincitore in tutti i gradi di merito, spetta lo stralcio di sanzioni e interessi oltre allo sconto del 95% sul­l’imposta.

 

abolizione della dichiarazione integrativa speciale

È stata abrogata la dichiarazione integrativa speciale che, al ricorrere di determinate condizioni ed entro soglie prestabilite, consentiva di sanare violazioni commesse nelle dichiarazioni fiscali, prevista dall’originario art. 9 del DL 119/2018.

 

Considerato che la relativa dichiarazione avrebbe dovuto essere trasmessa su un modello che avrebbe dovuto essere approvato dall’Agenzia delle Entrate, la stessa non ha mai avuto attuazione.

introduzione della sanatoria degli errori formali

Con il nuovo art. 9 del DL 119/2018 convertito viene invece stabilito che le violazioni di obblighi o adempimenti di natura formale che non incidono sulla determinazione della base imponibile delle imposte sui redditi, dell’IVA, dell’IRAP e sul pagamento di tributi possono essere sanate pagando 200,00 euro per tutte le violazioni commesse in ciascun periodo d’imposta.

Occorre a tal fine versare gli importi dovuti in due rate di pari importo (scadenti il 31.5.2019 e il 2.3.2020), e rimuovere la violazione.

 

Si deve trattare di violazioni commesse sino al 24.10.2018, non oggetto di atti di contestazione divenuti definitivi al 19.12.2018.

 

La natura di “violazione formale” può risultare non molto chiara, quindi per formulare ipotesi precise sulle violazioni che rientrano nella definizione è opportuno attendere i provvedimenti attuativi dell’Agenzia delle Entrate.

 

A titolo esemplificativo, possono rientrarvi le omissioni circa l’obbligo di comunicare, nella dichiarazione dei redditi, le minusvalenze o la mancata presentazione degli interpelli, oppure le violazioni contabili e sulla fatturazione che, in nessun modo, hanno avuto riflesso sull’imposta.

controlli per le imprese di medie dimensioni

Relativamente alla programmazione dei controlli fiscali, l’art. 16-quinquies del DL 119/2018 convertito prevede che, nei confronti dei contribuenti non soggetti agli indici sintetici di affidabilità fiscale né a tutoraggio, ci sarà una intensificazione dei controlli.

Ci sarà infatti, su base annuale, un piano di intervento coordinato tra l’Agenzia delle Entrate e la Guardia di Finanza, sulla base di analisi di rischio sviluppate mediante l’utilizzo delle banche dati nonché di elementi e circostanze emersi nell’esercizio degli ordinari poteri istruttori e d’indagine.

 

Il tutoraggio consiste nel controllo, potenzialmente su base annuale, dei contribuenti con volume di affari, ricavi o compensi non inferiori a 100 milioni di euro.

misure cautelari a favore dell’ente impositore

Ai sensi dell’art. 22 del DLgs. 472/97, l’Agenzia delle Entrate, sulla base del processo verbale di constatazione, dell’atto di contestazione della sanzione o dell’avviso di accertamento, può chiedere al Presidente della Commissione tributaria provinciale l’autorizzazione al sequestro preventivo o all’ipoteca dei beni del contribuente, nella misura in cui si dimostri il fondato pericolo per la riscossione.

 

Per effetto delle modifiche apportate dall’art. 16-septies del DL 119/2018 convertito, tale potere viene esteso alla Guardia di Finanza, che lo può esercitare sulla base del processo verbale di constatazione.

novità IVA per i commercianti al minuto

L’art. 17 del DL 119/2018 prevede l’estensione generalizzata dell’obbligo di memorizzazione e trasmissione telematica dei dati dei corrispettivi da parte dei soggetti passivi IVA che esercitano attività di commercio al minuto di cui all’art. 22 del DPR 633/72, a decorrere:

  • in generale, dall’1.1.2020;
  • dall’1.7.2019, per i commercianti al minuto con volume d’affari superiore a 400.000,00 euro.

 

Tali adempimenti sostituiscono l’obbligo di registrazione dei corrispettivi di cui all’art. 24 del DPR 633/72.

 

La disciplina del nuovo regime obbligatorio è stata in parte modificata in sede di conversione in legge del DL 119/2018.

Inoltre, in sede di conversione in legge è stata prevista la semplificazione delle regole per la tenuta con sistemi elettronici dei registri dei corrispettivi di cui all’art. 24 del DPR 633/72.

obbligo di trasmissione telematica dei corrispettivi

L’art. 17 del DL 119/2018 convertito prevede l’introduzione dell’obbligo di memorizzazione elettronica e di trasmissione telematica all’Agenzia delle Entrate dei dati dei corrispettivi giornalieri da parte dei commercianti al minuto (ossia da parte dei soggetti che effettuano operazioni ai sensi dell’art. 22 del DPR 633/72).

Viene dunque superato il precedente regime opzionale di memorizzazione e trasmissione dei dati di cui all’art. 2 co. 1 del DLgs. 127/2015.

Tuttavia, l’art. 17 del DL 119/2018 prevede che le opzioni esercitate entro il 31.12.2018 restano valide per il periodo d’imposta 2019.

Soggetti che trasmettono i dati al Sistema Tessera Sanitaria

In sede di conversione è stato previsto che tutti i soggetti passivi IVA tenuti a inviare i dati al Sistema Tessera Sanitaria, ai sensi dell’art. 3 co. 3 e 4 del DLgs. 175/2014 e dei relativi decreti del Ministero dell’Economia e delle finanze, possano adempiere l’obbligo di trasmissione dei corrispettivi mediante gli strumenti già previsti per l’invio dei dati al Sistema TS.

In precedenza, la semplificazione era stata prevista per i soli soggetti che effettuano cessioni di farmaci.

In sede di conversione in legge è stato altresì specificato che:

  • i soggetti in argomento adempiono il nuovo obbligo inviando al Sistema Tessera Sanitaria “tutti i corrispettivi giornalieri”;
  • i dati fiscali trasmessi al Sistema TS possono essere utilizzati solo dalle Pubbliche amministrazioni per finalità istituzionali.

 

Inoltre, viene precisato che i termini e gli ambiti di utilizzo dei suddetti dati, nonché le modalità tecniche di trasmissione, saranno definiti con decreto del Ministro della Salute, di concerto con i Ministri dell’Economia e della Pubblica amministrazione, sentito il Garante per la protezione dei dati personali, tenendo conto degli obblighi in materia di privacy di cui al Regolamento UE 2016/679.

Soggetti esonerati

Viene comunque prevista la possibilità di introdurre, mediante l’emanazione di successivi decreti ministeriali, specifiche ipotesi di esonero, in ragione della:

  • tipologia di attività esercitata dai soggetti passivi;
  • zona di esercizio dell’attività.

regole semplificate di tenuta del registro dei corrispettivi

L’art. 17 co. 1-bis del DL 119/2018, inserito in sede di conversione in legge, stabilisce regole semplificate per la tenuta dei registro dei corrispettivi con sistemi elettronici.

In particolare, viene previsto che la tenuta del registro dei corrispettivi, di cui all’art. 24 co. 1 del DPR 633/72, si considera regolare anche in difetto di trascrizione su supporti cartacei nei termini di legge (ossia entro tre mesi dal termine di presentazione della dichiarazione annuale dei redditi del periodo di riferimento), purché, in sede di accesso, ispezione o verifica, il registro medesimo:

  • risulti aggiornato sui sistemi elettronici;
  • venga stampato su richiesta degli organi procedenti e in loro presenza.

 

La disposizione in argomento:

  • estende quindi anche ai registri dei corrispettivi di cui all’art. 24 co. 1 del DPR 633/72 la semplificazione di cui all’art. 7 co. 4-quater del DL 357/94, finora prevista per i soli registri IVA delle vendite e degli acquisti di cui agli artt. 23 e 25 del DPR 633/72;
  • si applica a decorrere dal 19.12.2018.

proroga del reverse charge in alcuni settori

L’art. 2 co. 2-bis del DL 119/2018 convertito, modificando il co. 8 dell’art. 17 del DPR 633/72, proroga, dal 31.12.2018 al 30.6.2022, l’applicazione del meccanismo del reverse charge in alcuni settori, conformemente a quanto previsto dalla direttiva 2018/1965/UE.

In particolare, la proroga riguarda l’applicazione del reverse charge per le seguenti operazioni di cui all’art. 17 co. 6 lett. b), c), d-bis), d-ter) e d-quater) del DPR 633/72, vale a dire:

  • le cessioni di telefoni cellulari;
  • le cessioni di console da gioco, tablet PC, laptop e dispositivi a circuito integrato;
  • i trasferimenti di quote di emissioni di gas a effetto serra disciplinate dalla direttiva 2003/87/CE;
  • i trasferimenti di altre unità che possono essere utilizzate per conformarsi alla citata direttiva 2003/87/CE, nonché di certificati relativi al gas e all’energia elettrica;
  • le cessioni di gas e di energia elettrica a soggetti passivi-rivenditori ex 7-bis co. 3 lett. a) del DPR 633/72.

novità in materia di gruppo iva

L’art. 20 del DL 119/2018 ha esteso ai Gruppi Bancari Cooperativi, di cui all’art. 37-bis del DLgs. 385/93 (Testo unico bancario), la possibilità di optare per la costituzione di un Gruppo IVA di cui al Titolo V-bis del DPR 633/72, stabilendo che per i soggetti passivi partecipanti a tali Gruppi, ove stabiliti in Italia, il vincolo finanziario si considera sussistente in ragione dell’adesione al peculiare contratto di coesione di cui al citato art. 37-bis.

In sede di conversione in legge:

  • sono state introdotte ulteriori novità per i Gruppi Bancari Cooperativi;
  • è stato modificato l’art. 70-duodecies del DPR 633/72 al fine di disciplinare gli effetti dell’ade-sione al regime di adempimento collaborativo da parte di un soggetto partecipante a un Gruppo IVA.

Termini di esercizio dell’opzione per i Gruppi Bancari Cooperativi

È stata introdotta la possibilità, per i Gruppi Bancari Cooperativi, di costituire un Gruppo IVA con effetto dall’1.7.2019. L’art. 20 co. 2 del DL 119/2018 convertito stabilisce, infatti, che la dichiarazione per la costituzione del Gruppo IVA, se presentata da un Gruppo Bancario Cooperativo successivamente al 31.12.2018 ed entro il 30.4.2019, ha effetto dall’1.7.2019, purché sia stato preventivamente sottoscritto il contratto di coesione di cui all’art. 37-bis del DLgs. 385/93.

Rapporto tra Gruppo IVA e regime di adempimento collaborativo

L’art. 20 co. 1 lett. b-bis) del DL 119/2018, inserito in sede di conversione in legge, stabilisce che, nel caso in cui uno dei partecipanti a un Gruppo IVA aderisca al regime dell’adempimento collaborativo di cui al Titolo III del DLgs. 128/2015, quest’ultimo regime si estende obbligatoriamente a tutte le società partecipanti al Gruppo (in quanto unico soggetto passivo d’imposta).

Ciò vale anche nell’ipotesi in cui un soggetto abbia già aderito al regime di adempimento collaborativo e successivamente divenga parte di un Gruppo IVA.

Viene altresì stabilito che, nelle more del procedimento di adesione al regime di adempimento collaborativo da parte dei partecipanti al Gruppo IVA, l’esclusione dal regime medesimo prevista dall’art. 7 co. 3 del DLgs. 128/2015 non può essere dichiarata per cause connesse all’estensione al Gruppo IVA disposta dal nuovo co. 6-bis dell’art. 70-duodecies del DPR 633/72.

Rimborsi prioritari per i titolari di depositi fiscali di prodotti energetici soggetti ad accisa

In base a quanto disposto dall’art. 9 co. 12 del DL 119/2018, come modificato in sede di conversione in legge, i titolari di depositi fiscali di prodotti energetici soggetti ad accisa che si avvalgono del sistema informatizzato di controllo di cui all’art. 1 del DM 29.10.2009 n. 169 possono ottenere l’erogazione in via prioritaria dei rimborsi relativi a versamenti eccedenti rispetto alle imposte dovute, ove tali rimborsi siano richiesti entro i primi 6 mesi solari di ciascun anno.

Per beneficiare di tale agevolazione, occorre che i soggetti siano titolari della licenza di esercizio, non sospesa o revocata, di depositi fiscali di prodotti energetici di cui all’art. 23 co. 2 del DLgs. 504/95, aventi un parco serbatoi di stoccaggio di capacità non inferiore a:

  • 400 metri cubi per i depositi commerciali di gas e petroli liquefatti;
  • 000 metri cubi per i depositi commerciali di altri prodotti energetici.

 

La suddetta priorità si applica ai rimborsi erogabili a decorrere dal 19.12.2018, e comunque entro il limite di 10 milioni di euro annui per ciascun soggetto.

 novità in materia di “TERZO SETTORE”

L’art. 24-ter del DL 119/2018 convertito apporta alcune modifiche al Codice del Terzo settore (DLgs. 117/2017).

organizzazioni di volontariato

Con una modifica all’art. 33 del DLgs. 117/2017, viene previsto che le organizzazioni di volontariato (ODV) possono svolgere attività di interesse generale anche dietro versamento di corrispettivi che superano le spese effettivamente sostenute e documentate per la realizzazione di tale attività, a condizione che tali attività siano svolte in via secondaria e strumentale. In precedenza, invece, per l’attività di interesse generale, le ODV potevano ricevere soltanto il rimborso delle spese effettivamente sostenute e documentate.

Per effetto della modifica, quindi, le ODV possono svolgere la medesima attività di interesse generale:

  • verso il solo rimborso spese, in via principale;
  • verso il pagamento di corrispettivi superiori alle spese, in via secondaria.

titoli di solidarietà

Il DL 119/2018 convertito interviene sulla disciplina dei titoli di solidarietà di cui all’art. 77 del Codice del Terzo settore, estendendone l’operatività a favore di tutti gli enti iscritti al Registro unico nazionale del Terzo settore (RUNTS), comprese le imprese sociali e le cooperative sociali (in precedenza escluse).

Viene, inoltre, previsto che, se le somme raccolte dagli istituti emittenti non verranno impiegate a favore degli enti del Terzo settore entro 12 mesi dal collocamento dei titoli, esse saranno utilizzate per la sottoscrizione o per l’acquisto di titoli di Stato italiani aventi durata pari a quella originaria dei relativi titoli.

12.3 Soglia per la non commercialità delle attività degli enti

Viene introdotto il nuovo co. 2-bis all’art. 79 del DLgs. 117/2017, in base al quale le attività di interesse generale degli enti del Terzo settore si considerano non commerciali quando i ricavi non su­pe­rano di oltre il 5% i relativi costi per ciascun periodo d’imposta e per non oltre due periodi d’im­posta consecutivi.

L’efficacia di tale disposizione è subordinata all’autorizzazione della Commissione europea.

Detrazioni IRPEF per le erogazioni liberali agli enti del Terzo settore

Viene apportata una modifica all’art. 83 co. 1 del DLgs. 117/2017, relativo alle detrazioni IRPEF spettanti in relazione alle erogazioni liberali a favore degli enti del Terzo settore non commerciali, prevedendo che la detrazione “maggiorata” al 35% si applichi anche alle erogazioni liberali in natura (e non solo a quelle in denaro) effettuate a favore delle organizzazioni di volontariato.

Gli oneri sostenuti dal contribuente per le erogazioni liberali in denaro o in natura a favore degli enti del Terzo settore non commerciali di cui all’art. 79 co. 5 del DLgs. 117/2017 sono quindi detraibili dall’IRPEF:

  • nella misura del 30%, elevata al 35% qualora l’erogazione liberale sia a favore di organizzazioni di volontariato;
  • per un importo complessivo in ciascun periodo d’imposta non superiore a 30.000,00 euro.

Disciplina transitoria

Dal periodo d’imposta 2018 e fino alla decorrenza della nuova disciplina del DLgs. 117/2017, le disposizioni contenute nell’art. 83 si applicano in via transitoria alle:

  • Organizzazioni non lucrative di utilità sociale (ONLUS), di cui all’art. 10 del DLgs. 460/97, iscritte negli appositi registri;
  • organizzazioni di volontariato (ODV), iscritte nei registri di cui alla L. 266/91;
  • associazioni di promozione sociale (APS), iscritte nei registri nazionali, regionali e delle Provincie autonome di Trento e Bolzano, previsti dall’art. 7 della L. 383/2000.

 

In assenza di una specifica decorrenza, la detrazione elevata al 35% potrebbe spettare per le sole erogazioni liberali in natura a favore delle organizzazioni di volontariato effettuate dal 19.12.2018 (data di entrata in vigore della legge di conversione del DL 119/2018). Tuttavia, non è escluso che possa essere chiarito che la novità si applichi a tutto il periodo d’imposta 2018, sulla base del principio “dell’unitarietà del periodo d’imposta”.

Valutazione dei titoli iscritti nell’attivo circolante

L’art. 20-quater del DL 119/2018 convertito introduce una deroga ai criteri di valutazione in bilancio dei titoli iscritti nell’attivo circolante, che consente ai soggetti che redigono il bilancio secondo le disposizioni del codice civile e i principi contabili nazionali di mantenere, nei bilanci 2018, i medesimi valori risultanti dal bilancio precedente.

La deroga consente, in sostanza, di evitare la svalutazione dei titoli in base al valore di realizzazione desumibile dall’andamento del mercato, fatta salva l’ipotesi in cui la perdita abbia carattere durevole.

La disposizione ricalca quella introdotta dal DL 29.11.2008 n. 185, conv. L. 28.1.2009 n. 2 (c.d. “decreto anti-crisi”) per l’esercizio 2008, in considerazione dell’eccezionale situazione di turbolenza che aveva interessato i mercati finanziari, e successivamente prorogata fino all’esercizio 2012, dato il permanere della situazione di volatilità dei corsi.

Ambito oggettivo di applicazione

In relazione alla deroga prevista dal DL 185/2008, era stato chiarito che, nell’accezione della norma, il termine “titoli” doveva essere inteso in senso ampio, tale da ricomprendere sia i titoli partecipativi (azioni, quote di srl e strumenti finanziari assimilati), sia i titoli di debito (obbligazioni, titoli di Stato, quote di fondi comuni di investimento, ecc.).

Inoltre, in dottrina si riteneva non vi fosse alcuna preclusione all’applicazione della deroga ai titoli non quotati, stante il riferimento ai valori risultanti dal bilancio e non alle quotazioni delle Borse valori.

Si ritiene che tali indicazioni mantengano la loro validità anche in riferimento al regime derogatorio introdotto in sede di conversione del DL 119/2018.

Decorrenza

La disposizione riveste carattere transitorio.

La deroga si applica, infatti, con riferimento all’esercizio in corso al 24.10.2018 (data di entrata in vigore del DL 119/2018) e, quindi, in riferimento all’esercizio 2018, per i soggetti con esercizio sociale coincidente con l’anno solare.

La misura potrà, peraltro, essere estesa, con decreto del Ministero dell’Economia e delle finanze, agli esercizi successivi, “in relazione all’evoluzione della situazione di turbolenza dei mercati finanziari”.

Imprese di assicurazione

Il regime derogatorio si applica anche alle imprese di cui all’art. 91 co. 2 del DLgs. 7.9.2005 n. 209 (Codice delle assicurazioni private), sempre che redigano il bilancio secondo le disposizioni del codice civile e i principi contabili nazionali.

In questo caso, le modalità attuative e applicative delle disposizioni in esame sono stabilite dall’I­sti­tuto per la vigilanza sulle assicurazioni (IVASS) con proprio regolamento.

Le imprese del settore assicurativo applicano le disposizioni in esame previa verifica della coerenza con la struttura degli impegni finanziari connessi al proprio portafoglio assicurativo.

Inoltre, le imprese assicurative che si avvalgono della facoltà di non svalutare i titoli destinano a una riserva indisponibile utili di ammontare corrispondente alla differenza tra i valori registrati in applicazione della deroga e i valori di mercato alla data di chiusura del periodo di riferimento, al netto del relativo onere fiscale.

In caso di utili di esercizio di importo inferiore a quello della suddetta differenza, la riserva è integrata utilizzando riserve di utili o altre riserve patrimoniali disponibili o, in mancanza, mediante utili degli esercizi successivi.

14  riduzione del limite per l’interpello nuovi investimenti

Per effetto dell’art. 01 del DL 119/2018 convertito, che modifica l’art. 2 del DLgs. 147/2015, viene ridotta da 30 a 20 milioni di euro la soglia di investimenti in Italia per le istanze di interpello sui nuovi investimenti presentate dall’1.1.2019.

Si ricorda che l’investimento deve avere ricadute occupazionali significative e durature, mentre l’istanza può riguardare il trattamento fiscale del piano di investimento e le eventuali operazioni straordinarie che si ipotizzano per la sua realizzazione, ivi inclusa, ove necessaria, la valutazione in ordine all’esistenza o meno di un’azienda; la domanda può riguardare anche il giudizio preventivo sull’eventuale assenza di abuso del diritto fiscale o di elusione, la sussistenza delle condizioni per la disapplicazione di disposizioni antielusive e l’accesso ad eventuali regimi o istituti previsti dall’or­dinamento tributario.

agevolazioni fiscali per il comune di campione d’italia

L’art. 25-octies del DL 119/2018 convertito modifica la disciplina delle agevolazioni fiscali per il Comune di Campione d’Italia.

Viene infatti prevista la determinazione dei redditi prodotti, nel Comune di Campione d’Italia, in franchi svizzeri in base al tasso di cambio ridotto forfetariamente del 30% (per effetto della soppressione del limite di 200.000 franchi, la deduzione forfettaria opera per l’intero ammontare dei redditi).

Analoga agevolazione è prevista ai fini della determinazione del valore della produzione netta ai fini IRAP.

 

Possono beneficiare dell’agevolazione:

  • le persone fisiche iscritte nei registri anagrafici del Comune di Campione d’Italia, per i redditi IRPEF diversi da quelli d’impresa, prodotti in franchi svizzeri nel Comune di Campione d’Italia e/o in Svizzera;
  • i professionisti con studi nel Comune di Campione d’Italia, per i redditi di lavoro autonomo, prodotti in franchi svizzeri nel Comune di Campione d’Italia e/o in Svizzera;
  • le imprese individuali, le società di persone, nonché le società ed enti IRES residenti nel territorio dello Stato (art. 73 co. 1 lett. a), b) e c) del TUIR), iscritti alla Camera di commercio di Como e aventi la sede sociale operativa, o un’unità locale, nel comune di Campione d’Italia, per i redditi di impresa realizzati in franchi svizzeri nel Comune di Campione d’Italia.

abbattimento minimo per i redditi prodotti in euro

Tutti i redditi prodotti in euro dai soggetti interessati dall’agevolazione concorrono a formare il reddito complessivo al netto di una riduzione pari alla percentuale di abbattimento calcolata per i redditi in franchi svizzeri, con un abbattimento minimo di 26.000,00 euro.

Analoga agevolazione opera ai fini della determinazione del valore della produzione netta ai fini IRAP.

attività svolta fuori dal comune di campione d’italia

Nel caso in cui l’attività sia svolta anche al di fuori del territorio del Comune di Campione d’Italia, ai fini della determinazione del reddito d’impresa per cui è possibile beneficiare delle agevolazioni, sussiste l’obbligo in capo all’impresa di tenere un’apposita contabilità separata.

 

Le spese e gli altri componenti negativi relativi a beni e servizi adibiti promiscuamente all’esercizio dell’attività svolta nel Comune di Campione d’Italia e al di fuori di esso concorrono alla formazione del reddito prodotto nel citato Comune per la parte del loro importo che corrisponde al rapporto tra l’ammontare dei ricavi o compensi e altri proventi che concorrono a formare il reddito prodotto dall’impresa nel territorio del Comune di Campione d’Italia e l’ammontare complessivo dei ricavi o compensi e degli altri proventi.

compatibilità con i regolamenti “de minimis

L’agevolazione è riconosciuta nel rispetto del regolamento comunitario 1407/2013 che disciplina gli aiuti “de minimis”, nonché nei limiti del regolamento comunitario 1408/2013 per gli aiuti “de minimis” del settore agricolo.

16 regime sanzionatorio di favore per assegni privi di clau-sola di non trasferibilità

L’art. 9-bis del DL 119/2018 convertito stabilisce che, per le violazioni relative all’utilizzo di assegni privi dell’indicazione del nome o della ragione sociale del beneficiario e, soprattutto, della clausola di intrasferibilità per importi pari o superiori a 1.000,00 euro (come richiesto dall’art. 49 co. 5 del DLgs. 231/2007), l’entità della sanzione minima è pari al 10% dell’importo trasferito in violazione della predetta disposizione.

Ciò a due condizioni:

  • la violazione deve essere di importo inferiore a 30.000,00 euro;
  • devono ricorrere le circostanze di minore gravità della violazione ai sensi dell’art. 67 del DLgs. 231/2007 (avendosi riguardo, ad esempio, all’entità dell’importo, al grado di responsabilità, alla capacità finanziaria, all’assenza di precedenti violazioni).

 

Tale regime di minor rigore è applicabile anche ai procedimenti amministrativi in corso alla data di entrata in vigore del DL 119/2018 (24.10.2018).

IMPOSTA SUI “MONEY TRANSFER

L’art. 25-novies del DL 119/2018 convertito istituisce, a decorrere dall’1.1.2019, un’imposta sui trasferimenti di denaro, ad esclusione delle transazioni commerciali, effettuate:

  • verso Paesi non appartenenti all’Unione Europea;
  • da istituti di pagamento che offrono servizi di rimessa di somme di denaro.

 

L’imposta è dovuta nella misura dell’1,5% del valore di ogni singola operazione effettuata, a partire da un importo minimo di 10,00 euro.

Disposizioni attuative

Le modalità di riscossione e di versamento della suddetta imposta sui trasferimenti di denaro saranno stabilite da un apposito provvedimento attuativo del Ministero dell’Economia e delle finanze, d’intesa con l’Agenzia delle Entrate, che dovrà essere emanato entro il 17.2.2019.

operatori finanziari autorizzati al trasferimenti di denaro all’estero

Per espressa previsione normativa, i trasferimenti di denaro, ad esclusione delle transazioni commerciali, effettuati verso Paesi non appartenenti all’Unione Europea devono essere perfezionati esclusivamente su canali di operatori finanziari che consentono la piena tracciabilità dei flussi nel rispetto delle vigenti norme antiriciclaggio.

RIMOZIONE DEI VINCOLI PER la CESSIONE E LOCAZIONE DI EDIFICI IN REGIME DI EDILIZIA CONVENZIONATA

L’art. 25-undecies del DL 119/2018 convertito introduce alcune modifiche alla disciplina della rimozione dei vincoli di prezzo per la cessione delle unità abitative di edilizia residenziale pubblica (o del canone massimo di locazione).

Le novità intervengono su una complessa situazione di fatto, in cui gli acquirenti degli immobili di edilizia residenziale pubblica avevano venduto gli stessi, acquistati ad un prezzo vincolato, al valore di mercato. La Cassazione a Sezioni Unite, con la sentenza 16.9.2015 n. 18135, aveva affermato che il vincolo del prezzo massimo si applicava non solo al primo trasferimento, ma anche a quelli successivi, generando richieste di restituzione da parte degli acquirenti nei confronti dei venditori per la parte di prezzo eccedente il valore vincolato.

Al riguardo, il DL 119/2018 convertito:

  • introduce la possibilità di rimuovere i vincoli di prezzo massimo stabiliti per la cessione di unità abitative di edilizia residenziale pubblica da parte delle persone fisiche che vi abbiano interesse, anche se non più titolari di diritti reali sull’immobile (ossia i venditori), mediante atto pubblico o scrittura privata autenticata, e non più mediante convenzione (art. 31 co. 49-bis della L. 448/98);
  • dispone che, in pendenza della rimozione dei vincoli, il contratto non produce effetti limitatamente alla differenza tra prezzo convenuto e prezzo vincolato. Inoltre, è previsto che la rimozione dei vincoli di prezzo estingua eventuali richieste di restituzione, a qualunque titolo effettuate, della differenza tra prezzo convenuto e prezzo vincolato e rimuove qualsiasi vincolo di natura soggettiva (art. 31 co. 49-quater della L. 448/98);
  • sancisce l’applicazione delle nuove norme anche per i contratti aventi ad oggetto gli immobili a prezzo vincolato stipulati prima del 19.12.2018 (art. 31 co. 49-quater della L. 448/98).

CONTROLLI SULL’ESISTENZA IN VITA DI ASSICURATI o titolari di investimenti

Per contrastare il fenomeno delle polizze e dei depositi c.d. “dormienti”, l’art. 20-quinquies del DL 119/2018 convertito ha introdotto l’obbligo per le imprese di assicurazione e per gli intermediari di cui al DPR 116/2007 di verificare, entro il 31 dicembre di ciascun anno, l’esistenza in vita:

  • degli assicurati delle polizze vita;
  • degli assicurati delle polizze contro gli infortuni;
  • dei titolari di prodotti di investimento assicurativo;
  • dei titolari di rapporti di deposito di cui all’art. 2 del DPR 116/2007.

 

Se l’assicurato è deceduto, l’impresa di assicurazione:

  • attiva la procedura di corresponsione della somma dovuta al beneficiario;
  • provvede a ricercare il beneficiario, se non è espressamente indicato nella polizza.

 

Se il titolare del rapporto contrattuale con l’intermediario è deceduto, l’intermediario invia un invito ad impartire disposizioni da parte di possibili eredi legittimi, a mezzo raccomandata con avviso di ricevimento indirizzata all’ultimo indirizzo di residenza o domicilio comunicato o conosciuto del titolare, o a terzi delegati.

Vigilanza e sanzioni

La vigilanza sull’adempimento dell’obbligo di verifica spetta:

  • all’IVASS, in relazione alle imprese di assicurazione;
  • alla Banca d’Italia, in relazione agli intermediari.

 

Tali autorità, in caso di inadempimento, applicano le sanzioni previste dal Codice delle assicurazioni private, dal Testo unico bancario e dal Testo unico dell’intermediazione finanziaria.

Rinvio adeguamento delle banche popolari

L’art. 20 co. 2-bis del DL 119/2018 convertito proroga, dal 31.12.2018 al 31.12.2019, il termine entro il quale le banche popolari devono adeguarsi a quanto stabilito dai commi 2-bis e 2-ter dell’art. 29 del DLgs. 385/93 (Testo unico bancario) in sede di prima applicazione.

Tali disposizioni, in particolare, prevedono che:

  • l’attivo della banca popolare non può superare 8 miliardi di euro; se la banca è capogruppo di un gruppo bancario, il limite è determinato a livello consolidato;
  • in caso di superamento di tale limite, l’organo di amministrazione convoca l’assemblea per le determinazioni del caso. Se entro un anno dal superamento del limite l’attivo non è stato ridotto al di sotto della soglia né è stata deliberata la trasformazione in società per azioni o la liquidazione, la Banca d’Italia, tenuto conto delle circostanze e dell’entità del superamento, può adottare il divieto di intraprendere nuove operazioni ai sensi dell’art. 78 del DLgs. 385/93, o i provvedimenti previsti nel titolo IV, capo I, sezione I del medesimo DLgs., o proporre alla Banca centrale europea (BCE) la revoca dell’autorizzazione all’attività bancaria e al Ministero dell’Economia e delle finanze la liquidazione coatta amministrativa. Restano fermi i poteri di intervento e sanzionatori attribuiti alla Banca d’Italia dal DLgs. 385/93.

Offerta e consulenza su azioni di banche di credito coope-rativo

Per effetto dell’art. 20 co. 2-ter del DL 119/2018 convertito, quando la sottoscrizione o l’acquisto sia di valore nominale non superiore a 1.000,00 euro ovvero, se superiore a tale importo, rappresenti la quota minima stabilita nello statuto della banca per diventare socio, purché la stessa non ecceda il valore nominale di 2.500,00 euro, all’offerta ed alla consulenza aventi ad oggetto azioni emesse da banche di credito cooperativo (art. 33 del DLgs. 385/93) e da operatori bancari di finanza etica e sostenibile (art. 111-bis del DLgs. 385/93) non si applicano i seguenti articoli del DLgs. 58/98 (Testo unico dell’intermediazione finanziaria):

  • 21 (sui criteri generali nella prestazione dei servizi e delle attività di investimento e accessori);
  • 23 (sulla forma dei contratti);
  • 24-bis (sulla consulenza in materia di investimenti).

 

Ai fini del rispetto dei suddetti limiti si tiene conto degli acquisti e delle sottoscrizioni effettuati nei 24 mesi precedenti.

concessione della Mobilità in deroga nelle aree di crisi industriale complessa

L’art. 25-ter del DL 119/2018 convertito stabilisce che il trattamento di mobilità in deroga previsto dall’art. 1 co. 142 della L. 27.12.2017 n. 205 (legge di bilancio 2018) – previsto per i dipendenti occupati in aziende localizzate nelle aree di crisi industriale complessa ai sensi dell’art. 27 del DL 22.6.2012 n. 83 – venga concesso per 12 mesi anche in favore dei lavoratori che hanno cessato o cessano la mobilità ordinaria o in deroga dal 22.11.2017 al 31.12.2018, prescindendo dall’appli­cazione dei criteri di cui al DM 1.8.2014 n. 83473, previsti per l’erogazione degli ammortizzatori sociali in deroga.

Si conferma, inoltre, la necessità che ai predetti lavoratori siano contestualmente applicate misure di politica attiva, individuate in un apposito piano regionale, da comunicare al Ministero del lavoro e all’Agenzia nazionale per le politiche attive del lavoro (ANPAL).

 

Il lavoratore decade dalla fruizione del trattamento qualora trovi nuova occupazione a qualsiasi titolo.

proroga dell’Assegno di natalità (c.d. “bonus bebè”)

L’art. 23-quater del DL 119/2018 convertito dispone che l’assegno mensile di natalità (c.d. “bonus bebé”), già erogato in favore dei nuclei familiari per ogni figlio nato o adottato tra l’1.1.2015 e il 31.12.2018, sia:

  • riconosciuto anche per ogni figlio nato o adottato dall’1.1.2019 al 31.12.2019;
  • corrisposto esclusivamente fino al compimento del primo anno di età o del primo anno di ingresso nel nucleo familiare a seguito dell’adozione;
  • aumentato del 20% qualora si tratti della nascita o dell’adozione di un figlio successivo al primo.

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