A garage's taxable share jumped from 40% to 67%

Italy’s flat-rate regime does not tax what you earn. It taxes a fixed share of what you bill, and the share — the coefficiente di redditività, or profitability coefficient — is set by your activity, not by your accounts. Bill €50,000 on a 78% coefficient and the tax is calculated as though €39,000 of it were profit, whatever the year actually looked like.3

Which share applies comes from a nine-row table with a column of activity codes in it. On 1 April 2025 every Italian business got a new activity code. The table did not change.

For most activities that does not matter, because the old code and the new one land in the same row. For a car mechanic it matters a great deal. Repair used to sit beside vehicle selling, in the row at 40%. The new classification separates the two and files repair with the repair of computers and washing machines, in the row at 67%. Nobody chose it, nothing about the work changed, and on a €50,000 year the difference is €5,016 of net income. The rest of this piece counts how often that happens, and sets out why it is arguable that it should happen at all.

What the table actually names

The table is Allegato 2 to the 2019 budget law, which replaced Allegato 4 of the law that created the regime; the consolidated text has been in force since 1 January 2019.21 It has nine rows — food manufacturing at 40%, trade at 40%, street trade in non-food goods at 54%, construction and property at 86%, trade intermediaries at 62%, hospitality at 40%, the professions at 78%, and everything else at 67%. Its third column is headed, in the text still in force today: Codici attività ATECO 2007.

ATECO 2007 was retired. Since 1 April 2025 Italian business files carry ATECO 2025 codes, ISTAT’s implementation of the revised European classification, and the register moved existing businesses across using an operative reclassification table ISTAT publishes and keeps updating.45 The statutory table was not rewritten to match. So there are two ways to read it — against the code that used to be on your file, or against the one that is on it now — and for most activities they agree.

Twenty-five codes out of 1,239

ISTAT’s table carries 1,241 six-digit codes, the level a partita IVA actually declares. Two of them are set aside below because their destination is not in the statutory table at all. Of the remaining 1,239, 1,214 resolve to the same coefficient either way and 25 do not.6

Most of the 25 are what ISTAT calls complex recodes: the old code split, the business chose which successor fits, and the coefficient follows that choice. Five of those land on a whole branch rather than a single code, so the table alone does not fix an answer for them. Seven are different. They were recoded automatically, one old code to one new one, with nothing for the holder to decide.

The garages, moved without asking

Six of the seven are the motor trades. Under ATECO 2007 a garage sat in division 45, which the statutory table places in its wholesale-and-retail row at 40%: the classification put vehicle repair together with vehicle selling. The revised classification separates them. Repair moved to division 95, alongside the repair of computers and household goods, and division 95 sits in the residual row at 67%.

Nothing about the work changed. The presumed profit share on it rises by 27 points, from 40% of revenue to 67%.

What that is worth depends on billing. Holding everything else constant — the same revenue, the same 15% substitute rate, contributions at the Gestione Separata rate, no deductible costs — a mechanic billing €50,000 keeps €5,016 less a year on the 67% coefficient than on the 40% one.7

The gap widens with revenue, and the regime itself stops at €85,000 of billing — a separate edge with its own arithmetic, which we priced in an earlier piece.

Three numbers that changed meaning

Division 47 is the one place where the statutory table descends below the two-digit level and names individual classes: 47.81 for street trade in food and drink at 40%, and 47.82 together with 47.89 for street trade in other goods at 54%. Those numbers were chosen because that is what they described in 2007.

The revised classification dissolved the separate street-trade classes and folded itinerant traders into ordinary retail. It then reissued the numbers. In ATECO 2025, 47.81 is the retail sale of motor vehicles, 47.82 is the retail sale of vehicle parts and accessories, and 47.83 is the retail sale of motorcycles.5

Read literally against a current code, then, a shop selling car parts sits on the row the legislature wrote for market-stall traders, at 54% rather than the 40% its predecessor code carried. And 47.83 appears in none of the nine rows, because in 2007 there was no such class: the two motorcycle-retail codes that land there have no coefficient in the table at all.

What this does not settle

The count is arithmetic on two documents, and it is only that. No authority has been asked here which numbering the table means, and the wording that matters — the coefficient “previsto per l’attività esercitata”, provided for the activity carried on — can reasonably be read as attaching to the work rather than to the code that labels it. On that reading a mechanic keeps 40% and the table is simply out of date. On the other reading the code on the file governs, and seven activities changed band in April 2025.3

Nor does any of this say how many businesses are affected. The register publishes no breakdown of forfettario taxpayers by activity code that would let the 25 codes be weighted, so 25 out of 1,239 is a statement about the classification and not about the population.

The narrow point stands either way. A tax whose rate is written into a classification inherits every revision of that classification, and this revision moved six garage codes and a facade-cleaning code across a 27-point line while leaving the law that reads them unchanged since 2019. The full table is below, so any code can be checked directly rather than argued about.