CPB: the 150,000 euro threshold also applies when switching from flat-rate to simplified tax regime (cross-border guide)

Context

TL;DR

• Italian CPB flat-rate taxpayers bound for 2 years, even if switching to simplified regime.
• €150,000 revenue threshold for CPB exit, 50% above standard flat-rate exit threshold.
• Cross-border workers in Ticino can manage revenue fluctuations within €150,000 limit.
• CPB remains valid up to €150,000, but exceeds threshold terminates agreement.

Key facts

• Ruling Number: 87
• Publication Date: March 30, 2026
• Flat-rate Exit Threshold: €100,000
• CPB Exit Threshold: €150,000
• Legislative Decree: No. 13/2024
• Cross-border Workers: Ticino residents working in Lombardy
• Tax Regime Change: Switching from flat-rate to simplified regime does not invalidate CPB
• Revenue Monitoring: Taxpayers must monitor revenue to stay below €150,000 threshold

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.

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Operational details

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.

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Key points

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:

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