CPB: the 150,000 euro threshold also applies when switching from flat-rate to simplified tax regime
The Italian Revenue Agency has confirmed: those who joined the Biennial Preventive Agreement as a flat-rate taxpayer must respect the 150,000 euro revenue threshold, even after switching to the simplified tax regime. What changes for Ticino cross-border workers employed in Lombardy.
Contesto
On March 30, 2026, the Italian Revenue Agency published ruling no. 87, which clarifies a crucial point for Italian taxpayers who joined the Biennial Preventive Agreement (CPB) as flat-rate taxpayers and then transitioned to the simplified regime. The principle is straightforward: anyone who joined the CPB under the flat-rate regime remains bound by the rules of that regime for the entire two-year period, regardless of any changes in accounting practices. The case analyzed by the Agency concerns a taxpayer who, in 2023, operated under the flat-rate regime. By October 31, 2024, they had joined the CPB by completing the LM section of the Income Tax Return (Modello Redditi) in the dedicated flat-rate section. During 2024, the same taxpayer voluntarily switched to the simplified regime, despite remaining below the €100,000 revenue threshold that would have automatically excluded them from the flat-rate regime. The Agency clarified that this transition does not constitute grounds for exclusion or automatic termination of the CPB but does not alter the initial subjective qualification: the taxpayer remains bound by the limits applicable to those who joined as flat-rate taxpayers. The key point is the €150,000 revenue or compensation threshold, which represents the tolerance band introduced by the legislator with Legislative Decree No. 13/2024. For those who joined the CPB as flat-rate taxpayers, the exit threshold from the agreement is equal to the standard flat-rate regime exit threshold (€100,000) increased by 50%. This means that, up to €150,000 in revenue, the CPB remains valid, but once this threshold is exceeded, the agreement ceases to apply from the tax period in which the limit is surpassed. The Revenue Agency’s ruling introduces an important element of clarity for...
Dettagli operativi
For Ticino cross-border workers employed in Lombardy, the clarification provided by Italy’s Revenue Agency introduces an element of fiscal predictability worth careful analysis. The shift from the flat-rate regime to the simplified one is a choice many taxpayers consider due to greater accounting flexibility or business growth needs. However, once the CPB (Concordato Preventivo Biennale) has been adopted under the flat-rate system, the €150,000 revenue threshold becomes a critical parameter—even after changing regimes. ### Concrete scenarios for cross-border workers Let’s consider the case of a self-employed professional residing in Ticino but primarily operating in Lombardy. In 2023, they worked under the flat-rate regime with annual revenues of €90,000. By October 2024, they join the CPB as a flat-rate taxpayer, benefiting from greater fiscal stability. During 2024, their business grows, and revenues reach €120,000. Despite exceeding €100,000, they remain below the €150,000 threshold. In this case, the CPB remains valid: the taxpayer continues to enjoy the benefits of the agreement, even after exiting the flat-rate regime. If, however, 2024 revenues reach €160,000, the CPB ceases to apply from the same tax period. Income must then be calculated under the simplified regime rules, with ordinary taxation applied. Any advance payments made under the agreement must be recalculated, and the taxpayer loses the benefits of the agreement for that year. This scenario is particularly relevant for cross-border workers who, due to double taxation or divergent fiscal rules between Italy and Switzerland, must plan their revenues with great care. > 📊 Key takeaway: The €150,000 threshold applies regardless of the chosen fiscal regime. ### Comparing before and after the Revenue A...
Punti chiave
For cross-border workers from Ticino employed in Lombardy who joined the CPB (flat-rate tax regime) as flat-rate taxpayers, switching to the simplified regime does not alter the constraints of the €150,000 revenue threshold. This means it is crucial to continuously monitor your earnings and carefully plan your tax strategies. Below is a practical guide to managing this situation effectively. ### Step 1: Verify CPB status and revenue threshold The first step is to check whether you have already joined the CPB and under which conditions. If you joined as a flat-rate taxpayer in 2024, the €150,000 revenue threshold remains binding for the entire 2024-2025 biennium. To verify this: - Consult your 2024 tax return (Modello Redditi PF), specifically the LM section where CPB membership is indicated. - Check your 2024 revenue or compensation: if it exceeds €100,000 but remains below €150,000, the CPB remains valid even if you no longer qualify for the flat-rate regime. - If revenue exceeds €150,000, the CPB ceases to apply for 2024, and your income will need to be calculated under the simplified regime. 📊 Important: The €150,000 threshold applies to total revenue, including all sources of income. ### Step 2: Calculate revenue in real time To avoid unknowingly exceeding the €150,000 threshold, it is advisable to monitor revenue on a monthly or quarterly basis. This allows you to adjust your tax strategy in advance. For example: - If you anticipate exceeding €150,000 during the year, consider reducing revenue (e.g., by deferring invoices) or explore alternative tax planning options. - If revenue remains below €100,000, there are no issues: the CPB remains valid, and you can continue to benefit from its advantages. - If revenue falls between €100,000 and €150,000, the CPB i...
Punti chiave
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Frequently Asked Questions
- Can I switch from the flat-rate tax regime to the simplified regime without losing the benefits of the CPB?
- Yes. The Italian Revenue Agency has clarified that switching from the flat-rate regime to the simplified regime does not constitute either an exclusion or an automatic termination cause for the CPB. However, all rules applicable to flat-rate taxpayers remain in force, including the €150,000 revenue threshold. This means that, even after changing regimes, the taxpayer remains bound by the limits set for those who joined as flat-rate taxpayers.
- What is the maximum revenue threshold to maintain the CPB after switching to the simplified regime?
- The maximum threshold is €150,000 in revenue or fees. This threshold represents the tolerance range introduced by the legislator (Legislative Decree No. 13/2024), equal to the ordinary threshold for exiting the flat-rate regime (€100,000) increased by 50%. Exceeding €150,000 results in the termination of the CPB for the current tax period.
- What should I do if I exceed the €150,000 revenue threshold?
- If you exceed the €150,000 revenue threshold, the CPB ceases to apply from the same tax period in which the threshold is exceeded. Income must then be calculated according to the rules of the simplified (or ordinary) regime, and any advance payments made under the CPB must be recalculated. If you overpaid, you can request a refund; if you underpaid, you must make up the difference.
- Can I join the CPB for the 2025-2026 biennium if I exceeded the threshold in 2024?
- No. If you exceeded the €150,000 threshold in 2024, you can no longer benefit from the CPB in 2025. The threshold is binding for the entire tax period in which it is exceeded, and the CPB ceases to apply from that moment. For 2025, you will therefore need to calculate your income according to the rules of the tax regime you adopt.
- How can I monitor my revenue to avoid exceeding the €150,000 threshold?
- It is advisable to monitor revenue on a monthly or quarterly basis, for example using a simple Excel spreadsheet or accounting software. This way, you can take timely action to adjust your tax strategy, postpone certain invoices, or consider alternatives to avoid exceeding the limit.
- What are the deadlines to comply with for the CPB in 2025?
- For the 2025-2026 biennium, the deadline to join the CPB is 31 October 2025. By 30 November 2025, you must also pay the second advance payment of taxes for 2025. If you exceeded the €150,000 threshold in 2024, it is essential to recalculate the advance payments based on the new tax regime.
- Do I need to recalculate advance payments if I exceed the €150,000 threshold?
- Yes. If you exceed the €150,000 threshold, you must recalculate the advance payments of taxes based on the new tax regime (simplified or ordinary). Any advance payments made under the CPB must be adjusted: if you overpaid, you can request a refund; if you underpaid, you must make up the difference.