The Italian Revenue Agency, Inland RevenueHe clarified that the recognition of Italian citizenship granted to several family members through a single court ruling is subject to a single registration fee, fixed at 200 euros.
The guidance is contained in Response No. 196/2025, published on July 30. The question was raised by a taxpayer seeking to register a court ruling recognizing Italian citizenship not only for himself, but also for his daughter and two grandchildren, all born abroad.
The question was whether the registration tax should be paid separately by each person mentioned in the court decision or once for the deed as a whole.
Single sentence, single fee
The Agency found that the registration tax is levied on the legal nature of the act, not on the number of beneficiaries. This means that the analysis focuses on the legal content of the judgment and its legal effects—and not on the form or number of people involved.
In practice, some Italian courts have been demanding payment of the fee of 200 euros for each applicant included in the sentence, which significantly increased the costs for families seeking recognition of citizenship through judicial means.
According to Article 20 of the Single Text of the Registration Tax (DPR No. 131/1986), the charge must be based on the legal essence of the document. Article 21, however, distinguishes when there is more than one provision in a single document: if they are independent of each other, they are separate taxes. However, if they are inseparably connected, a single charge applies.
In the case of citizenship, there is no economic content to the decision. It is a legal recognition without financial consequences, which rules out the possibility of multiple taxes per person.
Rule for non-patrimonial acts
Article 8 of the Tariff, Part I, attached to the same decree, establishes that judicial acts without economic content are subject to the so-called imposed fissa, currently set at 200 euros. This category expressly includes judgments recognizing Italian citizenship.
Thus, even if it involves multiple family members, the court ruling is considered a single legal act for tax purposes. Therefore, a single fee payment is sufficient.
This understanding can be applied to other similar cases, whenever they involve judicial decisions that do not involve transfers of assets, money or other patrimonial effects.
