No More CU: Why Flat-Rate Taxpayers Must Review Invoices Carefully

Recent updates to Italy’s tax system have major implications for flat-rate taxpayers (regime forfettario). According to a report published in Italia Oggi, the elimination of the Certificazione Unica (CU) starting with the 2024 tax year is expected to make the flat-rate taxpayer invoice review process significantly more complex. Without this key document, taxpayers will face more challenges when calculating taxable income and preparing their 2025 returns.
This summary highlights the key takeaways from the original article and what they mean for expats, freelancers, and small business owners managing taxes in Italy.
What Changed for Flat-Rate Taxpayers?
Previously, if you were under the regime forfettario, your clients issued a CU each year, summarizing how much they paid you. You could simply check those forms, then add any other income—like payments from private individuals—not included in the CU.
But starting from 2024, this support disappears. For your 2025 tax return (on 2024 income), you’ll need to verify every payment manually. Why? Because under the cash basis method (principio di cassa), only income you actually received during the year is taxable—not what you invoiced.
More Risk of Compliance Issues
The Agenzia delle Entrate used to cross-check your tax return using CU data. Now, they’ll only have access to electronic invoices (fatture elettroniche)—which show amounts billed, but not necessarily paid.
This opens the door to confusion. The agency might send compliance letters or audit notices based on the assumption that all invoices were paid in full and on time. In reality:
- An invoice issued in December 2024 but paid in January 2025 is taxable in 2025, not 2024.
- If you received only part of a payment in 2024, only that portion should be included in your 2024 tax return.
- Unpaid invoices should not be counted until the money is actually received.
Legal Background
These changes stem from Legislative Decree 1/2024, which eliminated the requirement for clients to issue the CU for payments made to flat-rate taxpayers. The law assumes that electronic invoicing is now sufficient for tracking income.
But this is where problems arise: CU forms and invoices serve different roles. CU confirmed what was paid; invoices only show what was billed. For flat-rate taxpayers, this distinction is crucial—because taxes are due only on money actually received.
What Should You Do Now?
Here’s how to stay safe and compliant:
- Track every payment, not just issued invoices
- Work closely with a tax advisor to ensure your declared income matches actual receipts
- Keep payment confirmations, such as bank records or email receipts
- Prepare for more communication from the tax agency, which may be working with incomplete data
Final Thoughts
While this reform was intended to simplify tax reporting for flat-rate taxpayers, it actually increases complexity. Without the CU, you’ll need to rely entirely on your own records to prove income. The risk of errors—and audits—goes up.
Expath is here to help. We specialize in helping expats and freelancers navigate Italy’s evolving tax system with confidence. Whether you’re new to the regime forfettario or dealing with multi-year payments, we’ve got your back. Contact us now for an individual consultation.
Based on reporting by Giuliano Mandolesi & Pina Picciardo for Italia Oggi – April 1, 2025