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Ceilings21 August 2026 · 7 min read

Paid €100,001 instead of €99,999, a translator keeps €22,723 less — in that same year

Comma 54 of the regime's statute tests last year's receipts, so failing it can only close the regime from next January. The second sentence of comma 71, added on 1 January 2023, tests this year's — and above €100,000 the flat tax is withdrawn back to the previous 1 January, with VAT owed from the invoice that crossed the line.

In short
  • The €85,000 ceiling is an entry test on the previous year (comma 54 lett. a), so the year you pass it is unaffected — the regime ends the following January.
  • Receipts above €100,000 end it in the year itself: ordinary rules for the whole tax year, says the Agenzia delle Entrate's own 2026 return guidance.
  • For a professional on the 78% coefficient that is €22,723 of net income, and nothing is recovered until receipts reach €156,119.
  • It stops costing only if real business costs run to 38.6% of revenue — the level at which ordinary taxation was already the better place to be.
  • Both ceilings count money collected, not invoiced, and the €100,000 one is not scaled down for a business that opened mid-year.

A translator on Italy’s flat-rate regime, taxed on the 78% profitability share her activity carries, is paid €99,999 across 2026 and keeps €71,014.88 of it. The same translator, paid €100,001, keeps €48,291.87. Two euros more in the bank move €22,723, and they move it in the year the money arrives rather than the year after.112

€85,000 is the ceiling the statute sets and the one a commercialista quotes, and in the year you go past it, it costs nothing at all. The number that costs something is €100,000, and it works in a way the first one cannot.

One number tests last year, the other tests this one

The regime is granted by a list of conditions in comma 54 of article 1 of law 190 of 2014, and the first of them is about receipts nell’anno precedente — in the previous year — of no more than €85,000.8 It is an entry test, applied to a year that is already over. Comma 71 then says what happens when you fail it: the regime “cessa di avere applicazione a partire dall’anno successivo”, from the following year.7

Those two clauses fit together, and between them they make a mid-year expulsion impossible. Whatever you collect this year, this year was decided by last year’s figure. You always finish the year you are in.

The second and third sentences of comma 71 do not work that way. The regime “cessa di avere applicazione dall’anno stesso in cui i ricavi o i compensi percepiti sono superiori a 100.000 euro” — from that same year — and VAT is owed “a partire dalle operazioni effettuate che comportano il superamento del predetto limite”, from the invoices that carried you over.1 The Agenzia delle Entrate’s own instructions for the 2026 return put the consequence in one line: whoever falls out of the regime mid-year works out their income under ordinary rules per l’intero anno d’imposta, for the whole tax year.6

Why there are two of them

Because they were written eight years apart, for different purposes. Until the end of 2022 the regime had one ceiling, €65,000, and comma 71 stopped after its first sentence: there was no such thing as leaving the regime in the year you were in.2 On 1 January 2023 a single provision of the budget law changed both halves at once — comma 54 lettera a) raised €65,000 to €85,000, and comma 54 lettera b) added the two sentences that end the regime at €100,000.3

Read them together and the design is legible. The ceiling went up by €20,000, and a second, harder one arrived to stop the extra room being used as a one-year window: without it, someone could collect any amount at all in a year, pay 15% on a presumed fraction of it, and deal with the consequences from January. The first ceiling still cannot reach into the current year. The second one exists to do exactly that.

The edit was surgical, and one thing it did not touch is comma 82, which governs the reduced INPS contribution that artisans and traders inside the regime can elect. That comma still ends the discount “a partire dall’anno successivo” to the year a comma 54 or comma 57 condition fails, and it does not mention comma 71.4 So for a trader who crosses €100,000, the tax half of the regime disappears backwards to 1 January and the contribution half runs to 31 December.

What the crossing costs

The regime charges 15% on a fixed share of receipts, set by the activity’s ATECO group; the ordinary rules charge IRPEF at 23%, 33% and 43% on what is left after contributions, plus regional and municipal surcharges.910 At €100,000 of receipts and no deductible costs, that is the gap in the chart below: €71,015.59 against €48,291.46.

Figure 1Net income in the year of the crossing, 78% coefficient, 2026 rules

flat rate, 15% on 78% of receipts ordinary IRPEF

Computed with the TaxCompass tax engine at €250 steps, sampled every €2,500 for the chart. Gestione Separata 26.07%, 15% substitute rate, surcharges at the 2.23% national average, no deductible costs. The flat-rate line stops at €100,000 because the regime does; nothing is drawn across the gap.111

The €85,000 mark is on that chart and nothing happens there. The flat-rate line runs straight through it, because in the year it is passed the regime is still in force; what that crossing costs is a year of ordinary taxation starting the following January — a different number, and the subject of an earlier piece.

The €56,120 that buys nothing

A drop of this size takes a long time to climb back out of. Once the regime has gone for the year, every further euro is taxed at the ordinary marginal rate, and it takes €156,119 of receipts before the translator is back to the €71,014.88 that €99,999 would have left them. Everything collected between €100,001 and €156,119 — a band €56,120 wide — leaves them with less than stopping two euros earlier would have.12

How steep the drop is depends on the coefficiente di redditività, the fixed share of receipts the regime treats as profit. A lower share means a smaller taxable base, which makes the regime worth more, which makes losing it cost more. The band runs from €48,777 wide for a construction business on the 86% share to €90,991 for food and drink retail on 40%.

Figure 2The crossing, band by band, 2026 rules
ActivityShare taxedAt €99,999At €100,001Cost of crossingNo cost above
Food and drink retail40%€85,135€48,292€36,84365.1%
Other activities67%€75,102€48,292€26,81046.2%
Professionals78%€71,015€48,292€22,72338.6%
Construction86%€68,042€48,292€19,75033.1%

Net income in the year of the crossing at each statutory coefficient, no deductible costs. The last column is the share of revenue in real business costs at which the ordinary rules already do as well, so the crossing stops costing anything. The receipts that restore the same net income are in the CSV.128

What would make this go away

There is one thing that does, and it is worth knowing whether it applies to you. The flat regime ignores real business costs — the coefficient is the allowance, and a euro spent is a euro of take-home gone — while the ordinary rules deduct them before contributions and tax. So the cost of crossing shrinks as real costs rise, and at some level it disappears.

For the translator that level is 38.6% of revenue, about €38,550 of real annual costs on €100,000 of receipts. Below it, crossing still costs; above it, the ordinary rules were already the better place to be and the ceiling is doing the person a favour. The full curve is in the CSV, and the same comparison at lower revenue is the subject of another piece. It is not a prediction about any particular business; it is the point at which two computations meet.

It is measured on money received, not invoices sent

Comma 71 counts ricavi o compensi percepiti — receipts collected. So does comma 64, which builds the taxable base the same way.5 An invoice issued in December and paid in January belongs to January, and a client who pays late has moved the figure that decides the year. That cuts both ways, and it is the one part of this the person can see coming.

Two smaller things follow from the text. The entry ceiling in comma 54 is ragguagliato ad anno, scaled down for a business that opened mid-year; the word does not appear anywhere in comma 71, so €100,000 is €100,000 whether the activity ran for twelve months or two. And the third sentence makes VAT due from the operations that carried the person over — a tax the regime otherwise keeps them out of, and one they cannot deduct, as a piece on their foreign purchases sets out.

What this does not settle

The figures assume no deductible costs, one activity, contributions to the Gestione Separata, the 15% rate rather than the 5% start-up one, and surcharges at the 2.23% national average — a real address moves the ordinary side by up to €2,060 at this level, which is the range in the surcharge data. An artisan or a trader pays INPS on a different scale, so their number is not the translator’s.

Nor does any of this say how often the crossing happens. Whether the €100,000 sentence is a rule people fall over or a rule they steer around, we cannot tell from the statute, and no published breakdown of receipts around the threshold is available to us. The arithmetic below the line is what the rules produce; what people do about it is a different question.

forfettario-100k-same-year-2026.csvNet income in the year of the crossing at every €250 from €80,000 to €170,000, four coefficients, flat rate and ordinary rules side by side, 2026 parameters.forfettario-100k-cost-breakeven-2026.csvPer coefficient: the drop at the ceiling, the receipts that restore the same net income, and the level of real costs at which crossing stops costing anything.

Sources

  1. 1.Normattiva — L. 190/2014, art. 1, comma 71, secondo e terzo periodo (testo in vigore al 21 agosto 2026): «Il regime forfetario cessa di avere applicazione dall'anno stesso in cui i ricavi o i compensi percepiti sono superiori a 100.000 euro. In tale ultimo caso è dovuta l'imposta sul valore aggiunto a partire dalle operazioni effettuate che comportano il superamento del predetto limite»
  2. 2.Normattiva — L. 190/2014, art. 1, commi 54 e 71 nel testo in vigore al 31 dicembre 2022: la soglia d'ingresso è «euro 65.000» e il comma 71 si ferma al primo periodo, senza alcun limite di 100.000 euro
  3. 3.Normattiva — L. 197/2022 (legge di bilancio 2023), art. 1, comma 54: al comma 54 lett. a) «euro 65.000» è sostituito da «euro 85.000», e al comma 71 sono aggiunti in fine i periodi che introducono il limite di 100.000 euro
  4. 4.Normattiva — L. 190/2014, art. 1, comma 82 (testo in vigore al 21 agosto 2026): «Il regime contributivo agevolato cessa di avere applicazione a partire dall'anno successivo a quello in cui viene meno taluna delle condizioni di cui al comma 54 ovvero si verifica taluna delle fattispecie di cui al comma 57»
  5. 5.Normattiva — L. 190/2014, art. 1, comma 64 (testo in vigore al 21 agosto 2026): il reddito imponibile si determina applicando il coefficiente di redditività «all'ammontare dei ricavi o dei compensi percepiti»
  6. 6.Agenzia delle Entrate — Redditi PF 2026, fascicolo 3, istruzioni al quadro LM, p. 43: superata la soglia di 100.000 euro «il contribuente decaduto dal regime in corso d'anno è tenuto a determinare il reddito con le modalità ordinarie per l'intero anno d'imposta (Circolare n. 32/E del 5 dicembre 2023)» (PDF)
  7. 7.Normattiva — L. 190/2014, art. 1, comma 71 (testo in vigore al 13 agosto 2026): «Il regime forfetario cessa di avere applicazione a partire dall'anno successivo a quello in cui viene meno taluna delle condizioni di cui al comma 54 ovvero si verifica taluna delle fattispecie indicate al comma 57»
  8. 8.Normattiva — L. 190/2014, art. 1 commi 54–89 e Allegato 4 (regime forfettario, coefficienti di redditività)
  9. 9.Normattiva — TUIR art. 11, comma 1, testo in vigore dal 1-1-2026: 23% fino a 28.000 euro, 33% fino a 50.000 euro, 43% oltre
  10. 10.Normattiva — L. 335/1995, art. 2 (INPS Gestione Separata)
  11. 11.TaxCompass dataset — net income in the year of the crossing, at €250 steps from €80,000 to €170,000, under the flat regime while comma 71 still allows it and under the ordinary rules once it does not, four coefficienti, 2026 rules (CSV)
  12. 12.TaxCompass dataset — by coefficiente di redditività: what the crossing costs in the year it happens, how much must be collected before the ordinary rules return the same net income, and the level of real business costs at which the crossing stops costing anything, 2026 rules (CSV)

Every external figure above links to the document it came from. Datasets we produced are downloadable, so the arithmetic is checkable rather than taken on trust.

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