Italy offers neither immunity nor a flat tariff: it offers a fraction. The ravvedimento operoso lets you cure spontaneously by paying tax, interest and a penalty reduced to a share of the statutory minimum — a share that grows with time elapsed: from one-tenth for the briefest delays, to one-ninth within ninety days, one-eighth within the year, one-seventh within the second year, and larger fractions beyond. Every month of waiting buys the same peace at a slightly higher price — until the violation is formally established or an act arrives, and the price list closes entirely. No extraordinary amnesty is open: the one under law 197/2022 closed in November 2023 and covered only the distant past.
The two violations to cure together
An irregular crypto position almost always contains two autonomous violations, and the ravvedimento cures them separately. First: the omitted Quadro RW — monitoring, penalised at 3 to 15 percent of the undeclared value, per vintage. Second: the taxes — gains undeclared in the RT schedule (full penalties reaching 120 percent for an omitted return, 70 for an unfaithful one) and the unpaid two per mille. Both pass through an amended return and an F24, each with its own fraction. Curing one and staying silent on the other leaves standing exactly the inconsistency that data matching reads best.
Vienna forgives the sequence, Bern forgives once, Berlin demands the decade, Madrid bills by tariff, Paris grades by date. Rome does the most Italian thing of all: it discounts — and the discount expires a little every month.
Time as the price
The fraction logic turns the ravvedimento into an equation with a single variable: the calendar. The taxes owed do not change, interest runs regardless — what the filing date moves is the penalty's denominator. That is why the compliance letter is valuable information rather than a verdict: it certifies the window is still open and that someone is already looking. And that is why 2027, with the first DAC8 flows, is the implicit deadline of every undeclared position: after the automatic match, "established" stops being a remote hypothesis.
The sequence
- Reconstruct before deciding. Every open vintage, the right rate per year, documented costs, year-end values — the real number surprises, in both directions.
- Cure both violations together. An amended return with coherent RW and RT, an F24 for taxes, interest and fractions — one package, not corrections in instalments.
- Compute today's fraction against tomorrow's. The decision is made with numbers: every time threshold crossed raises the denominator.
- Pay together with the filing. The ravvedimento perfects on payment — an amended return without the F24 closes nothing.
- If an act has already arrived, change playbooks. Establishment or assessment closes the ravvedimento: from there you manage settlement, acquiescence or appeal — with representation.
Fractions, penalties and deadlines depend on facts and dates this page does not know. It frames the decision; it does not make it, and reading it creates no professional relationship.