{"id":73501,"date":"2026-07-29T17:39:08","date_gmt":"2026-07-29T15:39:08","guid":{"rendered":"https:\/\/www.lexia.it\/?p=73501"},"modified":"2026-07-30T11:11:59","modified_gmt":"2026-07-30T09:11:59","slug":"revenue-agency-circular-5e","status":"publish","type":"post","link":"https:\/\/www.lexia.it\/en\/2026\/07\/29\/revenue-agency-circular-5e\/","title":{"rendered":"Italian Revenue Agency Circular No. 5\/E of 16 July 2026 and the new mechanisms under the CCII: an operational framework for the early management of business distress"},"content":{"rendered":"\n

Circular No. 5\/E of 16 July 2026<\/a> marks the beginning of a broader initiative through which the Italian Revenue Agency seeks to provide a systematic reconstruction of the Code of Business Crisis and Insolvency (\u201cCCII\u201d). This first instalment is devoted to the mechanisms that have represented the greatest break with the former bankruptcy statute, examined not only in terms of their legislative evolution, but also in light of the explanatory reports, judicial guidance, and the principal issues that have emerged in practice. Although the document is confined to matters of direct or indirect relevance to the tax authorities, it is also significant for businesses, creditors, financial institutions, and professionals involved in restructuring and turnaround processes.<\/em><\/p>\n\n\n\n

In particular, the Circular offers a unified reading of the new framework, in which the timely detection of imbalances, the concreteness of restructuring prospects, and the effectiveness of negotiations assume a central role. The negotiated composition procedure, protective measures, the treatment of tax debt, the simplified composition with creditors, the restructuring plan subject to court confirmation, and the rules governing corporate groups are thereby brought within a single design: to address distress at an early stage, preserve the value of the business where possible, and reserve liquidation tools for cases in which no alternative solution is practicable.<\/em><\/p>\n\n\n\n

From a liquidation logic to the early management of business distress<\/strong><\/h2>\n\n\n\n

The Circular retraces the path that led the legislature to move away from the traditional bankruptcy model toward a system in which the preservation of the business, where feasible, is the primary objective. In this context, central importance is attached to the definition of \u201ccrisis\u201d as the likelihood of insolvency, measured by the inadequacy of projected cash flows to meet obligations falling due over the following twelve months, with the evident result of bringing forward the point at which the system requires the business to take action. This shift is completed by Article 3 of the Code of Business Crisis, which the Circular reads as establishing a permanent organisational safeguard, requiring the entrepreneur to put in place adequate arrangements capable of promptly detecting imbalances and reacting without delay.<\/p>\n\n\n\n

From an operational perspective, this approach has a pragmatic impact on the factual scenarios that arise in practice. The effective use of the foregoing instruments presupposes, in fact, a constant activity of monitoring and assessing the company\u2019s economic, asset and financial equilibrium, so as to enable difficulties to emerge at an early stage. From this standpoint, the adequacy of organisational arrangements, the reliability of information flows, and the ability to produce dependable forecasts take on substantive importance in defining restructuring strategies, rather than amounting to mere formal or ancillary compliance requirements.<\/p>\n\n\n\n

The negotiated composition procedure as the central juncture of the new system<\/strong><\/h2>\n\n\n\n

The most substantial part of the Circular is devoted to the negotiated composition procedure, which is described as a voluntary, confidential and out of court process for the consensual resolution of business distress, capable of being commenced exclusively at the initiative of the entrepreneur. As is well known, the mechanism does not constitute a formal insolvency proceeding, but rather operates as a framework for assessing whether there are concrete prospects of recovery and identifying the most suitable channel through which such recovery may be achieved.<\/p>\n\n\n\n

A first clarification of considerable practical importance concerns the subjective and objective scope of access. The Circular, also referring to the executive decree updated as of 23 April 2026 and the case law developed on the point, states that the negotiated composition procedure may also be used where a state of actual crisis or insolvency already exists, provided that there are concrete prospects of recovery and that the situation remains reversible from an economic and functional standpoint. The true fulcrum of the mechanism is thus identified in the \u201creasonable achievability\u201d of the restructuring, which must be assessed in concrete terms on the basis of the company\u2019s condition, the proposed measures, the seriousness of the negotiations, and the possibility of continuity, including indirect continuity through the transfer of the business or of business units.<\/p>\n\n\n\n

This approach entails a more rigorous scrutiny of the conditions for access and of the purposes actually pursued through the process. The Circular excludes the possibility that the negotiated composition procedure may be used for purely liquidatory purposes, particularly where the plan contemplates no prospect of business continuity and is aimed exclusively at suspending creditor action or at preparing a liquidation outcome already predetermined from the outset. It follows that, for the company, its advisers and its lenders, access to the negotiated composition procedure must be grounded on a reliable informational framework and on a concretely defined restructuring strategy, a generic representation of the debt situation being insufficient.<\/p>\n\n\n\n

From a documentary standpoint, the Circular accords decisive importance to the updated economic, asset and financial position and to the proposed restructuring plan, which must be consistent with the ministerial checklist and accompanied by a six month financial plan. These documents do not amount to mere formalities; rather, they serve a specific function: they are intended to measure the company\u2019s performance during the negotiations, enable the expert and the creditors to verify the soundness of the process, and distinguish cases in which deterioration remains manageable from those in which the scope for recovery has by then been exhausted.<\/p>\n\n\n\n

The role of the expert also emerges in strengthened form. The Circular underscores the expert\u2019s centrality both in the preliminary assessment of independence and professional adequacy, in facilitating negotiations, and in the ongoing verification that the process remains consistent with the objective of recovery. In operational terms, this makes the expert\u2019s report and the management of the adversarial dimension of the negotiations increasingly sensitive elements, including in view of any transition to court based instruments.<\/p>\n\n\n\n

Protective measures and relations with the banking sector<\/strong><\/h2>\n\n\n\n

The Circular devotes particular attention to protective and precautionary measures, clarifying their strictly instrumental function with respect to the successful outcome of the negotiations and the recovery of the business. In this regard, a distinction must be drawn between the provisional effectiveness of protective measures, which takes effect upon publication of the application in the Companies Register together with the expert\u2019s acceptance, and their subsequent confirmation by the court. Such confirmation does not follow automatically from access to the negotiated composition procedure, but presupposes verification of the actual existence of negotiations, the plan\u2019s not being implausible, and the concrete functionality of the requested protection in relation to the prospects of recovery.<\/p>\n\n\n\n

Judicial scrutiny also extends to the proportionality of the measures in light of the burden imposed on creditors and to their suitability for preserving negotiations that are genuinely under way. Protection cannot therefore amount to a merely dilatory moratorium aimed solely at paralysing enforcement action, but must form part of a concrete negotiating process conducted on the basis of complete information and in accordance with fairness and good faith. From this perspective, the Circular adopts a rigorous judicial approach toward applications based on plans lacking a credible prospect of continuity or otherwise incapable of outlining an effective path to rebalancing, which as such are not capable of being granted.<\/p>\n\n\n\n

Particularly significant, moreover, are the repercussions on banking relationships. The review of case law referred to in the Circular includes decisions which, where the necessary conditions were met, prohibited intermediaries from changing the classification of the exposure, reporting it as non performing, enforcing public or personal guarantees, setting off current account balances, or withdrawing certain credit facilities. In other cases, temporary suspension of loan repayments or an injunction against reporting to the Central Credit Register was ordered.<\/p>\n\n\n\n

The admissibility of such measures nonetheless remains subject to proof that the creditor\u2019s conduct may jeopardise serious negotiations and that the requested measure is concretely necessary for the restructuring, without prejudice to compliance with prudential supervisory rules.<\/p>\n\n\n\n

The treatment of tax debt within the negotiated composition procedure<\/strong><\/h2>\n\n\n\n

A distinct area of focus concerns the treatment of tax debt. During the negotiations, the entrepreneur may submit to the tax authorities a settlement proposal concerning the partial payment or deferred payment of tax liabilities, including taxes, penalties and interest. The sacrifice requested of the Treasury must, however, be supported by the certification of an independent professional, who is required to demonstrate the greater convenience of the proposal as compared with the alternative of judicial liquidation.<\/p>\n\n\n\n

In this context, the Circular also recognises the possibility of providing for partial payment of VAT claims, provided that an independent professional certifies that the proposed treatment ensures the tax authorities a recovery no less than that achievable in a liquidation scenario. Comparison with the liquidation alternative accordingly assumes decisive importance both in structuring the proposal and in its assessment by the competent offices.<\/p>\n\n\n\n

The proposal must also be submitted sufficiently in advance of the conclusion of the negotiations. The expression of the tax administration\u2019s position presupposes the conduct of a structured review process, including the acquisition of the necessary internal opinions and the establishment of an effective adversarial dialogue with the debtor. The submission of the application close to the expiry of the applicable time limit may therefore be regarded as contrary to the principles of fairness, good faith and mutual reliance where it does not allow the offices to carry out the required verifications.<\/p>\n\n\n\n

Corresponding to the entrepreneur\u2019s duty to act promptly is the obligation of the competent offices to conduct their review in accordance with criteria of efficiency and expedition, within a timeframe compatible with the needs of the restructuring process. The Circular thus outlines a procedural relationship based on cooperation, in which timely engagement constitutes an essential condition for the effective integration of tax debt into the negotiated solution.<\/p>\n\n\n\n

Incentive measures and the strategic importance of tax considerations<\/strong><\/h2>\n\n\n\n

Completing the framework, Article 25-bis <\/em>CCII provides for a series of incentive measures intended to encourage timely recourse to the negotiated composition procedure. From the date on which the expert accepts the appointment, interest accruing on tax debts is reduced to the statutory rate. Where the relevant conditions are met, tax penalties are reduced to the minimum amount and, for certain debts arising prior to access to the procedure, interest and penalties may be reduced by one half.<\/p>\n\n\n\n

The application of such benefits is not, however, uniform, but varies depending on the outcome of the negotiated composition procedure and the instrument through which the process is concluded. The incentive regime must therefore be assessed in light of the solution actually adopted, as well as any effects deriving from the subsequent commencement of liquidation proceedings.<\/p>\n\n\n\n

For certain outcomes expressly identified by the Code, and provided that the relevant solution is published in the Companies Register, there also apply the non relevance, for the purposes of determining business income, of positive extraordinary items deriving from debt reduction; the deductibility of bad debt losses without the need to prove the existence of certain and precise elements; and the creditor\u2019s right to recover the VAT relating to the unsatisfied portion of the claim by issuing a variation note.<\/p>\n\n\n\n

It follows that the treatment of tax debt cannot be deferred to the closing phase of the negotiations, but must be addressed from the time the plan is prepared. It affects the determination of cash flows, the overall treatment of creditors, the comparative convenience of the proposal, and the time required for its implementation. Tax sustainability therefore constitutes an essential component of the economic and legal feasibility of the restructuring process, and not a merely ancillary matter.<\/p>\n\n\n\n

The residual nature of the simplified composition with creditors<\/strong><\/h2>\n\n\n\n

Following the conclusion of the negotiated composition procedure, the Code provides for the simplified composition with creditors as a residual solution for the liquidation of the estate. The mechanism is available only after the unsuccessful outcome of the negotiated composition procedure, within sixty days from the communication of the expert\u2019s final report, provided that the negotiations were conducted in accordance with fairness and good faith and that negotiated debt restructuring solutions are not practicable.<\/p>\n\n\n\n

The Circular emphasises its autonomous character vis \u00e0 vis the liquidating composition with creditors and its collective insolvency nature, notwithstanding the simplified procedure and the absence of a creditors\u2019 vote. In this context, the expert\u2019s final report assumes central importance, since it must document the actual conduct of the negotiations, the behaviour of the parties, and the absence of any concretely viable alternative. It therefore constitutes an essential safeguard against the use of the negotiated composition procedure as a merely formal step toward a liquidation outcome planned from the outset.<\/p>\n\n\n\n

From a distributive standpoint, the Circular confirms compliance with the order of priority of lawful preferences, without prejudice to the possibility of providing for partial satisfaction of secured and preferred creditors within the limits of the realisable value of the encumbered assets. It follows that the simplified composition with creditors does not represent an ordinary liquidation alternative to the ordinary composition with creditors, but presupposes a genuine attempt at recovery and the documented impracticability of different solutions. The quality and transparency of the negotiating process therefore assume decisive importance for access to the mechanism.<\/p>\n\n\n\n

Notices by qualified public creditors: a softened early warning regime, but not an irrelevant one<\/strong><\/h2>\n\n\n\n

The rules governing notices issued by qualified public creditors confirm that the legislature has scaled back the original model, abandoning automatic triggering mechanisms and favouring instead a system of informational stimulus directed at the entrepreneur. The Circular clarifies that notice given upon the exceeding of debt thresholds does not impose any automatic obligation to commence a procedure, but constitutes an invitation to verify the equilibrium of the business and to assess possible recourse to the negotiated composition procedure.<\/p>\n\n\n\n

That said, this element should not be underestimated. Even in the absence of automatic consequences, it may be relevant in assessing the diligence of directors, the timeliness of the measures adopted, and the adequacy of the company\u2019s response to the first signs of deterioration. In other words, the progressive softening of early warning mechanisms does not lessen the relevance of such notices, but shifts the focus of the assessment to the adequacy of organisational arrangements and the timeliness of the initiatives adopted by the management bodies.<\/p>\n\n\n\n

Restructuring plan subject to court confirmation and corporate groups: the real systemic innovations requiring close attention<\/strong><\/h2>\n\n\n\n

Among the aspects of greatest systemic novelty, the Circular identifies the restructuring plan subject to court confirmation (piano di ristrutturazione soggetto a omologazione, or \u201cPRO\u201d) and the rules governing group crisis. As regards the PRO, the Circular highlights its discontinuity with ordinary distributive rules, in that it permits the free allocation of the value generated by the plan, even in derogation of the order of priority of lawful preferences, provided that the proposal is approved by all classes of creditors. This is a highly significant development, because it broadens the range of tools available for complex restructurings and requires professionals to exercise far more sophisticated judgment in the formation of classes, the negotiation of consensus, and the economic robustness of the plan.<\/p>\n\n\n\n

On the group side, the Circular emphasises the possibility of filing joint petitions accompanied by unitary or mutually connected plans, without prejudice to the autonomy of the assets and liabilities of each individual company. In such contexts, however, the professional\u2019s certification must make a qualitative leap, because it must describe the structure of the group, the equity or contractual links, and above all quantify the greater convenience for the creditors of each company deriving from the unitary approach as compared with separate plans. The Circular also notes that the autonomy of the estates remains unaffected for purposes of the treatment of tax claims as well, while allowing the submission of a unitary proposal for the treatment of tax debt in accordance with the criteria laid down in Article 284-bis CCII.<\/p>\n\n\n\n

For corporate groups experiencing financial stress, this means that procedural coordination does not eliminate the need for a rigorous perimeter analysis on an entity by entity basis, nor does it permit shortcuts in demonstrating the concrete benefit for each class of creditors. It is therefore foreseeable that some of the most delicate issues in terms of certification, classification, tax treatment and dispute management will arise precisely in the context of corporate groups.<\/p>\n\n\n\n

Concluding remarks<\/strong><\/h2>\n\n\n\n

Taken as a whole, Circular No. 5\/E of 16 July 2026 does not merely reconstruct the rules governing the new mechanisms under the CCII, but proposes a unified interpretation consistent with the progressive overcoming of the traditional liquidation based logic. Crisis prevention, the timely emergence of imbalances, the safeguarding of business continuity, the effectiveness of negotiations, and the selective use of protective and liquidation tools are the guiding principles along which the entire document develops. For market operators, the message is clear: the effectiveness of these instruments depends not only on their correct identification, but above all on the timeliness of the intervention, the reliability of the data, the adequacy of organisational arrangements, and the economic, financial and tax credibility of the plan.<\/p>\n\n\n\n

The negotiated composition procedure is confirmed as the principal path for the early and consensual management of business distress, whereas the simplified composition with creditors retains a strictly residual function. Notices by qualified public creditors reinforce the duty of management bodies to react promptly; the PRO and the rules governing corporate groups, in turn, expand the available scope for intervention, but require an increasing capacity to coordinate economic, corporate, insolvency and tax aspects. Rather than introducing a different method for applying the individual mechanisms, the Circular therefore calls for a change in the approach to business distress itself: to identify its warning signs at an early stage, govern its development through an integrated strategy, and resort to each instrument in accordance with its proper function and its own specific requirements.<\/p>\n","protected":false},"excerpt":{"rendered":"

Circular No. 5\/E of 16 July 2026 marks the beginning of a broader initiative through which the Italian Revenue Agency seeks to provide a systematic reconstruction of the Code of Business Crisis and Insolvency (\u201cCCII\u201d). This first instalment is devoted to the mechanisms that have represented the greatest break with the former bankruptcy statute, examined … Continued<\/a><\/p>\n","protected":false},"author":13,"featured_media":73502,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"inline_featured_image":false,"footnotes":""},"categories":[665],"tags":[],"area":[],"collana":[],"competenza":[1094],"class_list":["post-73501","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-publications","competenza-banking-restructuring-en"],"acf":[],"yoast_head":"\nItalian Revenue Agency Circular No. 5\/E of 16 July 2026 - LEXIA<\/title>\n<meta name=\"description\" content=\"Italian Revenue Agency Circular 5\/E\/2026: new CCII tools, negotiated settlement, PRO and early crisis management.\" \/>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/www.lexia.it\/en\/2026\/07\/29\/revenue-agency-circular-5e\/\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Italian Revenue Agency Circular No. 5\/E of 16 July 2026 - 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