Self-reported, administered or managed: who pays the tax and where losses end up

Sara has two securities accounts. On the first, held with an Italian bank, she made €3,000 of gains in 2026 without paying a cent of tax herself: the bank withheld €780. On the second, opened with a foreign broker, she must fill in section RT in May and pay with an F24 form. Same shares, same rate, two different tax lives, decided by the regime chosen for each account.

Why the consolidated text still says 12.50%

Read the consolidated text of Article 5 of Legislative Decree 461/1997 in the Gazzetta Ufficiale and you will find that miscellaneous financial income bears a substitute tax at 12.50 per cent. It looks authoritative, and it is wrong for 2026.

Article 7, on managed portfolios, prints the same figure. Neither sentence was ever redrafted, but the rate itself was changed by later laws, so a reader who stops at the consolidated wording falls straight into the trap.

Two texts now set the rate at 26%. The first is Article 3 of Decree-Law 66/2014, which from 1 July 2014 raised to 26 per cent the substitute taxes on miscellaneous income under letters (c-bis) to (c-quinquies) and, in paragraph 14, on managed portfolio results.

The second is the 2025 Budget Law, Law No. 207 of 30 December 2024. Paragraph 23 of its Article 1 states in so many words that the rate of the Article 5 substitute tax is 26 per cent.

The Revenue Agency's instructions point the same way. In section RT of the Redditi return, part II-A takes gains realised from 1 July 2014 that bear the 26 per cent tax, while part I-A is kept for older gains, taxed at 20% from 2012 to mid-2014 and at 12.50% up to 2011.

The figure in the consolidated text is therefore a piece of history rather than the 2026 rule. When a statute and the official return disagree, check which later law amended the rate.

The self-reported regime: doing it yourself

This is the default regime. It applies when the taxpayer has chosen nothing else or the intermediary offers no alternative, as is common with foreign brokers. Article 5 of Decree 461/1997 requires the tax to be paid directly, on the dates and in the manner used for the balance of income taxes shown in the return.

In practice the taxpayer gathers every sale made during the year, works out a gain or loss for each one, adds up the results and enters everything in section RT of the Redditi Persone fisiche return.

The section's instructions give tax code 1100 for payment. It covers gains under letters (c-bis) to (c-quinquies) as well as gains on qualifying shareholdings realised from 1 January 2025.

Its strength is flexibility: every gain and loss of the year, whichever account it comes from, meets in the same schedule. Its weakness is the workload and the risk of error. You must keep purchase and sale contracts, rebuild costs including fees and, when trading abroad, convert amounts into euros.

There is also a cash-flow effect. Under self-reporting the tax is paid with the following year's balance, months after the sale. For a gain made in January, payment comes the next summer. The advantage is modest but real, and it does not exist under the administered regime.

The administered regime: the intermediary steps in

Article 6 of Decree 461/1997 lets the taxpayer elect to have the tax applied to each gain as it is realised, provided the securities are held in custody or administration by a bank, an investment firm or another authorised entity.

The election is made by signed notice when the account is opened or, for existing accounts, before the tax year begins. It lasts for the whole year and can be revoked by the end of the calendar year, taking effect from the following one.

From then on the intermediary taxes every gain, positive differential or proceed. It pays the tax over by the fifteenth day of the second month after applying it, keeping it back from the sale proceeds. Under Article 5(3) the taxpayer has nothing to report for gains taxed under the Article 6 regime.

A technical detail changes the numbers compared with self-reporting. When the account holds several lots of the same category bought at different prices, the intermediary ignores purchase order and uses the weighted average cost of each homogeneous category, as Article 6(4) requires.

Under the administered regime, losses stay locked in the account where they arise. Article 6(5) has the intermediary deduct them from gains on later trades within the same relationship, in the same tax year and the following ones, but no later than the fourth.

A loss suffered at bank A does not automatically reduce the tax on a gain made at bank B, even when both accounts belong to the same person and hold the same kind of shares.

There is a way out. If the election is revoked or the account closed, unused losses can still be deducted, within the fourth year after they arose, from gains in another administered account held by the same persons, or in the tax return.

For this purpose the intermediary issues a certificate with the data needed. Anyone changing bank with losses on the books should ask for that document and keep it safe, because without it the losses are hard to prove.

Be careful with transfers. Article 6(6) treats moving securities to an account held by different persons, for instance from a sole account to a joint one, as a sale for consideration, unless the move results from inheritance or gift.

In that case the intermediary measures the gain on the value at the transfer date and may put the operation on hold until the taxpayer provides the cash to pay the tax.

The managed regime: taxing the year's result

The third regime is for people who have handed their assets to a manager under an individual discretionary mandate. Under Article 7 of Decree 461/1997 they may elect to be taxed on the result the portfolio accrues over the year rather than on individual trades, signing the election with the contract or before the tax year starts.

The result is found by taking the portfolio value at year end, adding withdrawals and subtracting contributions made during the year, then deducting the value at the start of the year. Income already subject to withholding and exempt income are also taken out.

The result is measured net of the mandate's costs and fees. The manager applies the substitute tax to it and pays it over by 16 February of the following year.

This regime has a feature the other two lack. Interest, dividends and gains of the managed assets all flow into the same result, and Article 7(3) switches off the ordinary withholdings on that income.

As a consequence, a loss on securities also lightens the tax burden on coupons, which is impossible under self-reporting or the administered regime. The price is the manager's fee.

If a year closes with a negative result, Article 7(10) allows it to be set against positive results of the following years, no later than the fourth, for the full amount that fits. The four-year horizon is the same one that governs losses in the other regimes.

Choosing a regime and filling in section RT

No regime wins in every case. The administered one suits people who trade with a single Italian intermediary and want to forget about the return. Self-reporting is almost unavoidable with a foreign broker, and helps anyone with losses in one account and gains in another, because it brings them together in the same year.

The managed regime makes sense for those who genuinely delegate the investment decisions and hold a portfolio rich in coupons and dividends, where netting losses against income is worth the fee.

Section RT of the Redditi Persone fisiche return is organised in parts that mirror the history of the rates. Part II-A is the standard one for gains under letters (c-bis) to (c-quinquies) realised from 1 July 2014.

Part III-A receives gains on qualifying shareholdings. Later parts deal with special cases, such as holdings in low-tax jurisdictions, and with crypto-assets, which have a course of their own.

The calculated-data part is where losses from earlier years are brought in. The instructions explain, for instance, that on line RT71 losses from the old part I are used at 76.92% of their amount, a practical application of the Decree-Law 66/2014 rule on losses born under lower rates.

A last point concerns timing. Legislative Decree No. 117 of 19 June 2026 repealed, with effect from 1 January 2027, the TUIR and Decree 461/1997 articles quoted in this course as part of a wider overhaul of income tax law.

For transactions carried out in 2026 the earlier versions described here still apply. From 2027 onwards the new texts will have to be read before relying on these rules.