Yesterday, March 12, 2026, the Ministry of Finance, acting under Legislative Decree 0150 of February 11, 2026 (economic emergency), issued Decree 0240, adopting extraordinary tax measures such as amendments to the Consumption Tax and the Net Worth Tax, tax relief measures, and the creation of the Tax Normalization Tax for 2026.The main points of the Decree are as follows:
The main provisions of the Decree are as follows:
1. Consumption Tax on games of chance and gambling operated exclusively on line
- Article 512-1 of the Tax Code is amended to include the provision of services related to games of chance and gambling operated exclusively online, defining the taxable event of the Consumption Tax as:
“(...) the monetary deposit, understood as cash payments or transfers of money or crypto-assets made by each bettor user to the operator of games of chance and gambling operated exclusively online, within the national territory or from abroad (...)
- The taxable base shall be the total amount of bets minus prizes paid during the corresponding two-month taxable period.
- The applicable rate shall be 16%
2. National-level tax relief measures
Taxpayers in default as of December 31, 2025, with respect to tax, customs, and foreign exchange obligations, may reduce penalties and default interest, provided that full payment of such amounts is made together with the principal obligation from the effective date of the decree through April 30, 2026.
a. Payment of 100% of the principal obligation.
b. Payment of default interest at a preferential rate of 4.5%.c. Payment of fifteen percent (15%) of the penalties, which may not be lower than the minimum penalty in force for the taxable year in which it was assessed.
- In the case of failure to file tax returns, the measure applies to returns omitted through November 30, 2025, provided they are filed by April 30, 2026, under the following conditions:
a. Payment of 100% of the principal obligation.
b. Payment of fifteen percent (15%) of the penalty, which may not be lower than the minimum penalty.
c. No default interest is required to be calculated or paid.
- In the case of amendments to tax returns, the measure applies to returns filed through December 31, 2025, provided the amended returns are filed by April 30, 2026, under the following conditions:
d. Payment of 100% of the principal obligation.
e. Payment of fifteen percent (15%) of the penalty, which may not be lower than the minimum penalty.
f. No default interest is required to be calculated or paid.
- In the case of formal obligations (for example, exogenous information reporting) not fulfilled as of November 30, 2025, the benefit applies if such obligations are complied with by April 30, 2026, and fifteen percent (15%) of the penalty is paid.
- The mechanism of administrative litigation settlement is enabled for tax, customs, and foreign exchange matters.
3. Tax Normalization Tax
- A Tax Normalization Tax is created for taxpayers holding omitted assets or non-existent liabilities as of April 1, 2026. The taxable base consists of the tax basis of omitted assets or the tax value of non-existent liabilities, and the applicable rate is 19%.
- Tax normalization shall not give rise to a net worth comparison nor to taxable net income resulting from the disclosure of omitted assets. Likewise, no penalties shall arise with respect to Income Tax and complementary taxes, substitute regimes for Income Tax, VAT, transfer pricing, exogenous information reporting, the annual return of assets held abroad, or the Net Worth Tax.
4. Net Worth Tax
- Paragraph 6 is added to Article 292-3 of the Tax Code, including as taxpayers subject to the Net Worth Tax legal entities and de facto companies that are Income Tax return filers, as well as permanent establishments (including branches) of foreign entities.
- It is clarified that legal entities in the healthcare sector, companies under government intervention, and public utilities companies located in the area affected by the declaration of economic, social, and ecological emergency contained in Legislative Decree 150 of 2026 are not taxpayers subject to the tax.
- For these entities, the taxable event is the ownership of net worth as of March 31, 2026, with a value equal to or greater than 200,000 UVT.
- A section is included for cooperatives under Article 19-4 of the Tax Code, stating that the value of the reserve for the protection of members’ contributions is excluded from the taxable base.
- To determine the net worth tax base applicable to permanent establishments (including branches) of foreign entities, a study must be prepared in accordance with the arm’s length principle, taking into account the functions performed, assets used, personnel involved, and risks assumed by the company through the permanent establishment or branch.
See: attached PDF document
This document is for informational purposes only and does not constitute legal or tax advice. It is recommended to assess the specific impact in each individual case.