1. A Regulatory Shift: More Than Just for Large Enterprises
The Tax Control Framework (TCF), once reserved for large enterprises under the Collaborative Compliance regime, is now accessible to small and medium-sized enterprises (SMEs) thanks to the Decree of July 9, 2025, implementing Article 7-bis of Legislative Decree 128/2015.
This optional regime enables SMEs to adopt a structured fiscal risk control system without meeting traditional size thresholds, unlocking new benefits and incentives from the Italian Revenue Agency.
2. Key Benefits for SMEs
- Suspension of administrative and criminal penalties, if risks are communicated in advance
- Faster communication channels with tax authorities and reduced audit timeframes
- Greater legal certainty and fewer tax disputes
- More efficient use of internal resources through a structured process
These benefits are especially appealing to growing SMEs seeking transparency and reputational strength in an increasingly complex tax environment.
3. A Strategic Opening
The threshold for TCF certification eligibility will gradually lower:
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€750M (2025)
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€500M (2026)
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€100M (2028)
This marks a cultural and operational turning point. SMEs now have the chance to:
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Build trusted relationships with tax authorities
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Show fiscal reliability to investors and partners
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Gain a competitive edge by adopting structured compliance
4. Challenges to Implementation
Adopting a TCF system does require commitment. SMEs need to:
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Document their tax strategy, risk mapping and processes
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Undergo independent certification by qualified professionals
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Adapt their organizational structure, even without a dedicated tax office
While the benefits are clear, manual management is inefficient and error-prone. This is where digital solutions become essential.
5. eDIMI: The Digital Support SMEs Need
eDIMI, developed by Luptax, is the first Italian software specialized in TCF management.
It helps SMEs and large enterprises alike to:
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Create and manage a structured risk-control matrix
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Plan controls and assign responsibilities
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Automate deadlines and alerts
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Collect audit-ready documentation
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Generate files required by the Revenue Agency
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Support the certification process under the new regime
With eDIMI, SMEs can comply more easily and efficiently, gaining access to the advantages of collaborative compliance with reduced administrative burden.
6. Conclusion
The expansion of the Collaborative Compliance regime to SMEs is not just regulatory—it’s strategic. It offers a real opportunity to improve fiscal governance, reduce disputes, and build trust.