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Editor in chief: Angelo Scorza
04/11/19 09:49

The new real estate tax on marine platforms (IMPI) will be introduced from 2020

The PKF TCL firm analyzes the objective and subjective assumptions for the application of the new tax

The tax decree number 124 of 26th October 2019 introduced the "Property tax on marine platforms" from 2020, that is called IMPI.

This new tax is different from the IMU (the real estate tax on properties), and it will replace any other ordinary local real estate taxation on the same artifacts.

It should be noted that all the platforms that are destined for the cultivation of hydrocarbons and that are located in the territorial sea, as defined by Article 2 of the Navigation Code, fall within the definition of marine platforms.

With regard to the tax bases, we should consider the accounting values ​​identified for the buildings classifiable in the cadastral group D, specifying that the provision for a flat-rate reduction of the tax bases of 20%, as established in the previous version, is eliminated.

A tax rate of 10,6 per thousand will be applied to the tax bases as determined above, with the clarification that the taxation related to the 7.6 per thousand portion will be reserved to the State and the difference (taxation related to the remaining 3 per thousand ) will be attributed to the Municipalities, which must be identified by a specific decree which must be issued within 180 days from the date of entry into force of the fiscal decree.

As for the payment of the tax, only for 2020 this can be paid in a single solution (by December 16) to the State, which will allocate the amount due to the Municipalities that will be identified in the ministerial decree. While for tax periods after 2020, the payment must be made to both the State and the Municipality.

The assessment and tax collection will be carried out by the Municipalities and to these will be allocated the largest sums deriving from the performance of the activities by way of tax, interest and penalties.

Finally, it should be noted that the rules regarding deductibility from business income and self-employment income provided for the IMU, and non-deductibility for IRAP purposes are applicable to IMPI. In detail, a deductibility of 60% is envisaged for the tax period subsequent to 31 December 2019 and in progress at 31 December 2020 (2020-2021 for company with calendar year); equal to 70% for the tax period subsequent to December 31, 2021 (2022 for company with calendar year ) and equal to 100% for the tax period after December 31, 2022 (2023 for company with calendar year).


Stefano Quaglia

Irene Angeletti

PKF Studio TCL - Genova Milano


Crowdfounding also through the placement of bonds and debt securities for SMEs and innovative start-ups

Among the main innovations introduced to the crowdfounding regulation, approved by Consob, there is the possibility for SMEs and innovative start-ups to offer on the crowdfounding portals, also bonds or other "financial debt instruments", or "securities" such as debt securities, bills of exchange and short-term minibonds.

It should be noted that before this change, small and medium-sized companies could raise funds by selling only share of their capital on crowdfunding platforms.

With regard to the possibility of subscription, reference should be made to the text of the law which states that: «the subscription of bonds or debt securities is reserved, within the limits established by the civil code, to professional investors and to particular categories of investors identified by Consob and it is carried out in a section of the portal different from that in which the collection of equity».

The civil code excludes small investors from the category of possible investors, contrary to what happens for those who invest in equity crowdfunding, since an investment in the equity of a startup or an SME will have a lower risk profile than an investment in a debt security.

With regard to the right given to Consob to "identify particular categories of investors", it is limited by the Civil Code which establishes that the subscription of debt securities issued by the Srls and obligations, in the cases provided for by Article 2142, must be reserved for investors professionals subject to prudential supervision.

It follows that to be able to invest in this type of securities and bonds will not be small investors but professional investors and other particular investors such as:

1. Those who hold a portfolio of financial instruments, for a value that exceeds € 250,000;

2. Those who undertake to invest at least 100,000 euros in offers of this kind, who are aware of the risks associated with the investment

3. retail investors, in the context of portfolio management or investment advisory services

Barbara Pollicina

Matteo Maccio

PKF Studio TCL - Genoa Milan

TAG : Tax corner