Biennial Preventive Agreement (CPB): What You Need to Know in 2025
Italy’s new Biennial Preventive Agreement (Concordato Preventivo Biennale – CPB) offers eligible professionals and businesses the opportunity to agree in advance on their taxable income for two years, reducing audit exposure and increasing fiscal predictability. Introduced by Legislative Decree no. 13 of 12 February 2024, the regime is now entering into force with practical details confirmed by the Ministerial Decree of 28 April 2025.
Legal Framework
The CPB is grounded in national tax legislation and implemented through ministerial regulations, most notably the April 2025 decree, which outlines the methodology for calculating agreed income for the 2025–2026 tax years.
Purpose and Eligibility
The CPB is aimed at self-employed individuals and businesses subject to Synthetic Reliability Indexes (ISA). By accepting the Revenue Agency’s income proposal, taxpayers benefit from protection against tax audits for the agreed period.
Key points:
Applicable to taxpayers active in 2024 in sectors like agriculture, manufacturing, trade, services, and professions
Excluded from 2025 onward: taxpayers under the forfait regime
Access and Requirements
To qualify, taxpayers must:
Apply ISA indexes
Be active in 2024
Be fiscally compliant (no unpaid debts above €5,000, unless under a payment plan)
Excluded taxpayers include:
Forfait regime taxpayers (from 2025)
Those with omitted returns, in liquidation or insolvency, or convicted of tax-related crimes in the past five years
Methodology and Calculation
The Revenue Agency’s proposal is based on:
Taxpayer’s historical data (2022–2024)
ISA scores and sector averages
Broader macroeconomic indicators
ISA score-based adjustments apply:
+10% for ISA score of 10
+15% for scores 9–10
+25% for scores 8–9
Extraordinary income variations may lead to further adjustments ranging from –30% to +50%.
Opting In and Revocation
The official software “IlTuoISA_CPB 2025” is available from 30 April 2025
Opt-in/revocation must be submitted via the Redditi 2025 tax return, using:
Code “1” to accept
Code “2” to revoke
Deadline: 30 September 2025
Legal Effects
Adhering to the CPB grants several benefits:
Exemption from audits (analytical, synthetic, presumptive) for the agreed income
No need for a compliance certificate (visto di conformità) when offsetting tax credits (within thresholds)
Ongoing eligibility depends on compliance with all filing and payment obligations
Tax Compliance
Agreed income must be declared in the annual return
Prepayments (IRPEF, IRAP) are calculated using the agreed income
Deviation from the CPB agreement may result in loss of audit protection
Practical Considerations and Risks
The CPB is beneficial only when the proposed income aligns with economic reality.
Taxpayers should:
Assess whether fixed income taxation over two years is appropriate
Consult a tax advisor before opting in
Be aware: variations exceeding ±30% from the agreed income may lead to revocation of benefits
💡 Practical Example: How the Agreed Income Works
Declared income in 2023: €80,000
Agreed income for 2024: €90,000
ISA Score: 9
Calculation:
Income increase: €10,000
Applicable substitute tax rate for score 9: 12%
Substitute tax due: €10,000 × 12% = €1,200
🧾 Result: The taxpayer pays €1,200 on the incremental income agreed under the CPB.
