The Italian tax-compliance certificate commonly known as DURF may exempt qualifying contractors and subcontractors from the enhanced payroll-withholding verification procedures under Article 17-bis of Legislative Decree no. 241/1997.
One of the most technical conditions requires qualifying payments recorded over the relevant three-year period to equal at least 10% of the revenue or fees reported in the tax returns for the same period. Revenue Agency Ruling no. 174/2026 confirms that this test should not be read on a purely formal basis.
The key principle is that taxes economically attributable to the company may be relevant even where the physical payment is made by another person or does not flow directly through the Italian tax account.
What the DURF certificate is for
Article 17-bis applies to certain contracts for works or services exceeding €200,000 per year where the additional statutory conditions are met, including prevalent use of labour at the customer’s premises and use of equipment attributable to the customer.
Where the exemption is unavailable, contractors must provide the customer with the information and payment evidence needed to verify withholding taxes relating to employees directly engaged on the relevant works or services. A valid certificate allows qualifying businesses to avoid those enhanced procedures.
The 10% tax-payment condition
In addition to the 10% test, the statutory framework requires, among other matters, at least three years of business activity, compliance with tax-return obligations and the absence of specified overdue collection debts above the statutory threshold, subject to the rules on suspensions and instalment plans.
The 10% ratio can be particularly difficult for companies whose Italian corporate income tax balance is reduced by withholding taxes, foreign tax credits or tax already borne outside Italy.
Withholding taxes on bank interest
Ruling no. 174/2026 first addresses withholding taxes applied to interest earned on bank balances and deposits and reported in line RN15 of the Italian corporate income tax return. The tax is paid to the Treasury by the intermediary, but economically belongs to the tax position of the company receiving the interest.
The Revenue Agency therefore allows these amounts to be taken into account in the 10% calculation. The analysis focuses on the tax burden attributable to the company rather than only on who physically submits the payment.
Foreign taxes and the Article 165 tax-credit limit
The second clarification is relevant to Italian companies with international contracts or foreign-source income. Taxes paid abroad do not pass through the Italian tax account, yet they may still be relevant for the DURF test.
They may be counted only up to the amount recognised as a foreign tax credit under Article 165 of the Italian Income Tax Code and reported in line RN13 of the corporate income tax return. The full foreign tax paid is not automatically included.
A related 2026 ruling: payments following automated tax notices
The September ruling follows another clarification issued earlier in 2026. Ruling no. 63 of 3 March 2026 accepted payments made through the F24 system to settle automated tax-compliance notices for purposes of the 10% calculation, provided the payments fall within the relevant three-year time window.
Taken together, the guidance points towards a substantive assessment of the company’s tax reliability rather than an exclusively mechanical reading of amounts physically paid by the company itself.
Operational checklist
Items to review before requesting a DURF
01 · Last three corporate income tax returns
02 · Revenue or fees for the relevant three-year period
03 · F24 payments recorded in the tax account
04 · Bank-interest withholding taxes reported in RN15
05 · Article 165 foreign tax credits reported in RN13
06 · F24 payments for automated tax notices
07 · Other components accepted by Revenue Agency guidance
08 · Collection debts and current instalment plans
If the issued certificate omits relevant amounts
Where a certificate does not reflect all components that the company considers relevant, the three-year calculation should be reconciled in detail and the competent Revenue Agency office should be asked to review the certificate. Ruling no. 174/2026 also notes that an advance tax ruling is not the procedural tool for challenging the content of a certificate already issued.
FAQ
How long is a DURF valid?
The certificate is valid for four months from its issue date.
Do bank-interest withholding taxes count towards the 10% test?
Yes. Ruling no. 174/2026 treats them as taxes economically attributable to the company even though the intermediary makes the physical payment.
Can the full amount of foreign tax be counted?
No. The amount is limited to the foreign tax credit recognised under Article 165 of the Italian Income Tax Code.
Can payments following automated tax notices count?
Yes, under Ruling no. 63/2026, where they are paid through F24 within the relevant three-year period.
Official sources
FC Consulting & Management assists companies and corporate groups with Italian tax compliance and the obligations connected with contracts, withholding taxes and fiscal regularity.
This contribution is for information purposes only and does not replace an assessment of the individual company’s position.