Tax debt audits
In general, public administrations and companies with predominantly public participation, before making, for any reason, the payment of an amount exceeding 5,000 euros, verify, also electronically, whether the beneficiary is in default of the payment obligation deriving from the notification of one or more payment orders for a total amount equal to at least that amount. If so, they do not proceed with the payment and report the circumstance to the collection agent competent for the territory, for the purposes of carrying out the collection activity of the sums registered in the register.
Exceptions to the block, however, are those for which installment plans have been started and payments are regular, or if there has been a suspension.
The new rules for professionals
In the case of professionals, the mechanism that comes into force from 15 June, however, provides for a direct deduction or deduction system. It involves three steps:
- the PA carries out the electronic check before paying the fee, whatever its amount;
- if a registered debt of 5,000 euros or more emerges, the public body pays the amount necessary to cover the tax bill directly to the Collection Agent;
- if the invoice has an amount greater than the debt, the professional receives the residual sum.
Here are three practical examples that illustrate the application of the verification and reduction mechanism for professionals in the technical and construction area (engineers, architects, surveyors, geologists, etc.), taking into account the cash principle in force from 15 June 2026.
Example 1: Works Management for a Municipality (invoice under 5,000 euros)
- Professional: architect in charge of the works management for the renovation of a municipal school.
- Accounting situation: presents a fee for the second down payment of 3,500 euros.
- Tax situation: he has a notified and unpaid tax bill of 7,200 euros for failure to pay VAT in previous years.
- What the PA does: the Municipality activates the mandatory electronic verification (even if the invoice is less than 5,000 euros). the system detects debt above the critical threshold.
- Payment outcome: the Municipality carries out the “block with total deduction”. It orders the payment of all 3,500 euros directly to the Revenue-Collection Agency. The architect receives 0 euros in his bank account, but his tax debt drops to 3,700 euros.
Example 2: Technical Administrative Testing (Invoice higher than debt)
- Professional: structural engineer who issues an invoice for the static testing of a bridge under the jurisdiction of the Province.
- Accounting situation: amount of the service equal to 12,000 euros.
- Tax situation: has a debt due for tax bills (e.g. social security contributions not paid to Inarcassa and passed to compulsory collection) equal to 5,500 euros.
- What the PA does: the Province queries the collection system before issuing the mandate. Default is found above 5,000 euros.
- Payment outcome: partial deduction is triggered. The Province pays 5,500 euros to the Collection Agent (fully extinguishing the professional’s tax bill) and credits the difference of 6,500 euros to the engineer’s current account.
Example 3: Final design with installment debt (no block)
- Professional: surveyor who invoices a regional body for the skills for the subdivision and design of a building project.
- Accounting situation: invoice amount equal to 6,000 euros.
- Tax situation: he has a total tax bill of 15,000 euros, but he has obtained an active installment plan from the Revenue Agency and is paying the installments regularly.
- What the PA does: the Region carries out the preventive electronic control.
- Payment outcome: the Collection IT system reports that the debt is “suspended/regularized” thanks to the ongoing installment payment. The Region does not make any reduction and pays the entire amount of 6,000 euros to the surveyor.
Summary table
The following table illustrates the practical application of controls and sanctions on the remuneration of professionals (ex art. 54 TUIR) depending on the amount of the invoice and the amount of the tax debt recorded in the register.
|
Professional Invoice Amount |
Amount of Tax Debt per Roll (Files) |
Preventive BP control |
Payment Outcome / Operational Effect |
|---|---|---|---|
|
Any amount (even <5,000 euros) |
No debt or regularized debt (e.g. active installment payments) |
YES (Mandatory for any amount) |
Regular payment: The PA pays the entire compensation to the professional. |
|
Any amount (even <5,000 euros) |
Less than 5,000 euros |
YES (Mandatory for any amount) |
Regular payment: The debt below the threshold is detected but does not trigger the reduction. The amount is paid in full. |
|
Any amount (e.g. invoice of 3,000 euros) |
Equal to or greater than 5,000 euros (e.g. 6,000 euro tax bill) |
YES (Mandatory for any amount) |
Total reduction of the invoice: The PA pays the entire amount of the invoice (3,000 euros) to the Collection Agent. The professional receives 0 euros. |
|
Higher than the debt (e.g. invoice of 8,000 euros) |
Equal to or greater than 5,000 euros (e.g. 5,000 euro folder) |
YES (Mandatory for any amount) |
Partial reduction: The PA pays 5,000 euros to the Collection Agent to settle the tax bill and pays the remaining 3,000 euros to the professional. |
>> If you want to receive news like this directly on your smartphone, subscribe to our new Telegram channel!
Thank you for subscribing to the newsletter.