The Ministry of Economy and Finance (MEF), with the decree of June 27, 2025, clarified the fiscal relevance of the accounting entries introduced by OIC 34, regulating phenomena of uncertain qualification and classification.
The regulator has deactivated the application of enhanced accrual for lower revenues that are recorded and estimated on a bulk basis rather than analytically. These lower revenues refer to legal or contractual penalties and estimated returns. In both cases, these accounting entries will have fiscal relevance for IRES and IRAP purposes only when their existence becomes certain and the amount can be objectively determined.
The decree also regulates the costs associated with obtaining a contract (such as an agent’s commission), which, if capitalized as intangible assets and amortized, are deductible within the limit of the portion attributable to each fiscal year.
The principle of enhanced accrual is also not applied in two additional cases:
- Loss-making contracts: Contracts where the company commits to fulfilling an obligation whose expected costs exceed the agreed benefits. At the time the commitment is undertaken, the company must recognize a provision for the liability assumed. This provision will become deductible for tax purposes only when the initially estimated costs become certain and determinable.
- Bonus competitions: The cost is recognized as a provision without adjusting revenue. These amounts will assume fiscal relevance at the time the cost is actually incurred.
