Company car fringe benefits: Transitional regime introduced by the so-called 'Decreto Bollette'

In particular, article 1, paragraph 48 of the Law 207/2024 amended article 51, paragraph 4, lett. a) of the TUIR, establishing that, for newly registered vehicles made available for mixed use under contracts signed from January 1, 2025, the value of the fringe benefit shall be calculated on a flat-rate basis, assuming 50 per cent of the value corresponding to 15.000 km per year, determined according to ACI costs and net of any deductions from the employee.

The new system adopts a criterion based on the vehicle’s fuel type, granting reductions in the rate in the following cases: 

In this regulatory context, the system is designed to support the use of electric vehicles while discouraging the allocation of vehicles powered by internal combustion engines, regardless of their emission levels. According to what Assonime highlighted in circular n. 7 of April 3, 2025, the objective of the reform is clearly to guide corporate choices towards more sustainable solutions. However, a genuine possibility for transition cannot disregard the presence of adequate infrastructure, which currently remains unevenly distributed across the national territory.

In parallel, the Revenue Agency has clarified that reimbursements paid by the employer to the employee for electricity expenses incurred for home charging of company vehicles provided for mixed use, constitute employment income and are therefore subject to ordinary taxation. Such reimbursements cannot be classified as fringe benefits, as clarified in the response to a ruling request, n. 421 of August 25, 2023, and confirmed in the responses provided during a meeting with the press on February 5, 2025. This guidance requires companies to carefully assess the methods of reimbursement, also from the perspective of compliance with tax regulations.

Assonime has also highlighted a significant issue in the new regulation, namely, the absence, in its original formulation, of a transitional regime capable of safeguarding vehicles that had already been ordered or assigned prior to the entry into force of the new rules.

In order to guarantee a gradual energy transition and in accordance with the principles of proportionality and progressiveness, a legislative amendment was therefore introduced to address the gap created by the initial reform. For this purpose, article 6, para. 2-bis of the legislative decree 19/2025 (so-called “Decreto Bollette”), introduced during the conversion into Law 60/2025, added the new paragraph 48-bis to article 1 of law 207/2024, which provides that the previous regulations continue to apply in the following cases:

In such cases, the value of the fringe benefit will continue to be determined based on the carbon dioxide emission level, according to the following percentages:

It should be noted that, according to resolution n. 46/2020 of the Revenue Agency, the date of assignment is determined by the signing of the assignment agreement by both the employer and the employee for the provision of the benefit.

Despite the introduction of a transitional regime, some uncertainties remain, particularly regarding vehicles registered by 2024 but provided for mixed use in 2025. Such cases do not appear to fall within either the previous regulations, which apply to contracts signed by December 31, 2024, or to vehicles ordered before that date, nor within the new regulations, which apply exclusively to newly registered vehicles. In absence of official clarifications, it may become necessary to apply the normal value criterion provided for in Article 9 of the TUIR, as already indicated by the Revenue Agency in previous official guidelines.

According to this approach, the fringe benefit should be determined by subtracting from the normal value of the vehicle the ACI per-kilometre allowance multiplied by the kilometres travelled in the interest of the employer. This criterion aims to assign tax value exclusively to the private use of the vehicle, excluding the portion attributable to work-related activity. However, as noted by Assonime, the application of this criterion would involve operational and management complexities, particularly regarding the accurate determination of the share of private use.

Therefore, the introduction of the transitional regime has exceptionally allowed for the previous method of calculating the fringe benefit, based on CO₂ emissions, to be maintained, in order to protect vehicles that were already ordered or assigned by the end of 2024. This approach provides regulatory continuity and increased certainty for businesses, although some specific cases remain unresolved and will require official guidance to ensure correct implementation.

In conclusion, the evolving regulations on car fringe benefits represent a key issue for companies, which must reconsider their corporate vehicle policies with a focus on sustainability and tax compliance.​