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Filing a tax ruling request (interpello) with the Agenzia delle Entrate

Before adopting a tax-relevant course of action on which a tax rule is objectively uncertain, you can ask the Agenzia delle Entrate for its opinion with a ruling request (istanza di interpello), written on plain paper and free of stamp duty, addressed as a rule to the Regional Directorate of your tax domicile and filed by hand, by registered post with acknowledgement of receipt or by PEC. The Agenzia answers within 90 days; if it stays silent, the solution you proposed applies. The request does not suspend any tax deadline.

Up to date for 2026 — verified on September 25, 2026Official procedure, no printed formGuide: about 60 min

Deadlines

Before the course of action
For conduct that is reported in a tax return, before the ordinary return deadline and before the related tax obligations are met; afterwards the request is inadmissible
Within 30 days of the office's invitation
Completing a request that lacks information other than identification and the description of the situation
Within 90 days of filing
The Agenzia's answer; within 60 days of receiving additional documents, if requested. The period is suspended from 1 to 31 August

Documents to prepare

  • A detailed, documented description of the concrete and personal case
  • The tax provisions whose interpretation, application or disapplication is requested
  • The interpretation you propose
  • Contact details, including electronic ones, for receiving the answer
  • The signature of the applicant or legal representative, or the power of attorney of the appointed professional
See the procedure on the official site

No form is attached to this procedure: the link leads to the official page that describes it.

What this page gives you

The guide above and the link to the official site. ActioFin does not produce any document for this page: whatever you fill in or file is done on the official medium.

Who this applies to

  • The taxpayer, or whoever is required by law to carry out tax obligations jointly with them or on their behalf, who has a concrete and personal doubt about state taxes before acting
  • Ordinary ruling: interpretation of an objectively uncertain tax rule; qualifying ruling: classification of a situation (for instance advertising or entertainment expenses)
  • Anti-abuse ruling: opinion on whether a transaction is abusive, for any tax; disapplication ruling: setting aside an anti-avoidance rule that limits deductions, tax credits or allowances
  • Not the evidentiary ruling, which since Legislative Decree 219/2023 is reserved to taxpayers in the cooperative compliance scheme and to those filing a new-investment ruling, except for the VAT group case
  • Not a professional or trade association acting for its clients or members without a specific mandate

Worked example

Studio Bianchi srl, Bologna, and an expense between advertising and entertainment

Studio Bianchi srl, whose revenue is far below 100 million euros, plans to spend 18,000 euros on a client event and does not know whether it counts as advertising or entertainment expense. Before closing its accounts and filing its return, the director sends a qualifying ruling request by PEC to the Emilia-Romagna Regional Directorate: company details and tax code, a detailed description of the event, the rules in doubt, contact details, the proposed solution (advertising) and a digital signature. If the Agenzia does not answer within 90 days, the proposed solution is deemed accepted; if it answers otherwise, the company may decide not to follow it, but no payment or filing deadline has been suspended in the meantime.

How to fill it in, step by step

  1. Check that your doubt concerns a concrete and personal case on state taxes, that the rule is objectively uncertain and that the Agenzia has not already given the answer in circulars, resolutions, principles of law or published rulings.
  2. Choose the type of ruling (ordinary, qualifying, anti-abuse, disapplication) and state it expressly in the request.
  3. Write the request on plain paper with the taxpayer's identification details and tax code, a precise description of the situation, the provisions to be interpreted or set aside, contact details including electronic ones for the answer, and the solution you propose.
  4. Have it signed by you, the legal representative or the attorney appointed under article 63 of Presidential Decree 600/1973, attaching the power of attorney if it is not written at the foot of the request.
  5. Address it to the Regional Directorate competent for your tax domicile, or to the Taxpayers Division if you are non-resident, have turnover or revenue of at least 100 million euros or are a central administration.
  6. File it before acting, preferably by one channel only: hand delivery, registered post with acknowledgement of receipt or PEC, with a digital signature or a handwritten signature plus a copy of an identity document.
  7. If the office asks you to complete the request, reply within 30 days; then wait for the answer without suspending payments or returns.

Good to know

  • The Agenzia's opinion does not bind the taxpayer, who may choose not to follow it; it does bind the offices, which cannot issue tax or penalty assessments contrary to it where the facts found match those described.
  • The answer also covers the taxpayer's later conduct in the same situation, unless it is corrected, with effect for the future only.
  • The answer to a ruling request cannot be appealed.
  • Pending the ministerial decree, filing the request does not require payment of the contribution provided for by article 11(3) of the Taxpayers' Statute.
  • The rules described are those of article 11 of Law 212/2000 as served by the Agenzia in 2026.
  • If an act of the Agenzia has already been served on you and you believe it is wrong, the tool is the self-correction request (istanza di autotutela), not a ruling.

Common mistakes

  • Filing the ruling request after already acting or after the return deadline: the request is inadmissible.
  • Describing the case in general terms: without a concrete and personal situation the request is inadmissible.
  • Asking for an opinion on a matter already under an audit of which you have been formally informed.
  • Raising questions of fact or on non-tax rules, such as establishing tax residence.
  • Relying on the ruling request to postpone a payment or a return: deadlines are not suspended.

Frequently asked questions

How long does the Agenzia take to answer a ruling request?

Within 90 days of filing or of the request being completed; if it asks for additional documents, within 60 days of receiving them. The period is suspended from 1 to 31 August.

What happens if the Agenzia does not answer?

Silence counts as consent to the interpretation proposed by the taxpayer in the request.

Where is the ruling request filed?

As a rule with the Regional Directorate competent for the tax domicile, by hand, by registered post with acknowledgement of receipt or by PEC. Non-residents, large taxpayers and central administrations file with the Taxpayers Division.

Does a ruling request cost anything?

The request is written on plain paper and is not subject to stamp duty; the contribution provided for by the Statute is not due until the ministerial decree governing it is adopted.

Can I appeal against the answer?

No, the answer to a ruling request cannot be appealed; the taxpayer may however decide not to follow it.

Go further

Related forms

Official sources

Read in Italian

Guide and document provided for information purposes only; they do not constitute personalised legal or tax advice. Check the recipient organisation's requirements and consult a professional if needed.