Flat-rate tax or flat-rate regime for short-term rentals in Genoa: which is more convenient in 2026

A Change of Tax Season: 2026 Redraws the Rules

For years, the flat-rate rental tax (cedolare secca) has been the quasi-automatic tax regime for those renting out apartments for short periods: simple, flat, with no need to open a VAT number. From January 1, 2026, however, things have changed structurally. The 2026 Budget Law (Law no. 199/2025, in force from January 1, 2026) has significantly rewritten the tax rules for those managing short-term rentals in Italy. These are not marginal adjustments: the tax rates are changing, the threshold beyond which one becomes an entrepreneur is changing, and the practical obligations to comply with are changing.

For Genoa property owners who have one or more residences in the heart of Genoa to generate income from, understanding which tax regime to choose — flat-rate rental tax or flat-rate regime with VAT number — is today more important and more complex than in the past. This article analyzes the updated regulatory framework, the mechanisms of the two main regimes and the concrete implications depending on the number of properties managed, with particular attention to the Genoa market context.

The 2026 Regulatory Framework: What Really Changed

The most relevant point of discontinuity concerns the threshold beyond which short-term rental activity is considered entrepreneurial. Starting in 2026, those in Italy offering short-term rentals of more than two properties must pay particular attention to the new limits introduced by the 2026 Budget Law, which has reduced from four to two residential units the threshold beyond which the exercise of a business activity is presumed. Until 2025, it was permitted to apply the flat-rate rental tax to short-term rentals of up to four residential units without being considered an “entrepreneur.” From 2026, anyone renting out more than two apartments on a short-term basis in the same fiscal year is automatically considered to be engaged in a business activity.

The new system is therefore structured in three levels, clearly defined by the regulations:

• 1 property in short-term rental: flat-rate rental tax at 21% (at the taxpayer’s choice in the tax return). For those managing a single property in short-term rental, the flat-rate rental tax rate of 21% remains confirmed. This choice protects families who use a second home or unused apartment as an income supplement.
• 2 properties in short-term rental: flat-rate rental tax at 21% on the first (at choice) and 26% on the second. Those owning two properties in short-term rental can still operate as private individuals, but with differentiated taxation: flat-rate rental tax at 21% on the first property (at the taxpayer’s choice) and 26% on the second. This progression reflects greater taxpaying capacity compared to occasional rental of a single apartment.
• 3 or more properties in short-term rental: legal presumption of business activity, obligation to open a VAT number. The real revolution concerns those managing three or more properties. From the third property onwards, the presumption of business activity is automatically triggered, with the obligation to open a VAT number and the impossibility of continuing to apply the flat-rate rental tax.

A technical aspect often overlooked: from 2026 it is not the number of bookings or turnover that counts, but the number of residential units intended for short-term rental in the fiscal year. And furthermore: the count of properties is made per cadastral unit — if multiple rooms in the same apartment are rented with separate contracts, this still counts as a single property. Finally, it is worth remembering that the presumption of entrepreneurial status does not apply if the taxpayer grants two apartments under short-term rental contracts and two others under ordinary rental contracts or at agreed rates.

A note on sanctions and the risks of reclassification: the term “relative legal presumption” deserves attention. This is not an absolute presumption: the taxpayer who exceeds the numerical threshold has the right to prove, with suitable evidence to the contrary, that the activity does not have the characteristics of a business. However, as flagged by a tax study, tax judges, in ruling no. 148/2026 of the Court of Tax Appeal of first instance in Florence (March 2, 2026), valued elements such as a high number of bookings, continuity over time and use of online platforms. The case concerned a single residential unit, with years prior to the new 2026 threshold: the entrepreneurial qualification was triggered below any normative numerical threshold.

Flat-Rate Rental Tax: Simple, But Not for Everyone

The flat-rate rental tax is the preferential tax regime that allows property owners to pay a fixed substitute tax instead of taxing rental income with ordinary IRPEF (personal income tax). Its advantages are well known: the owner can choose to subject the income derived from rent to a tax that replaces IRPEF, related surcharges and, if the contract is registered, registration and stamp duties. No VAT number is needed, nor electronic invoices, nor registration with the Chamber of Commerce.

The fundamental limitation is that the tax rate applies to the entire amount collected: there is no provision for any flat-rate deduction of costs. Those who incur significant expenses for management (cleaning, maintenance, OTA commissions, furnishings) “lose” them completely for tax purposes. With an LLC or with a VAT number under the ordinary regime, management costs can be deducted, utilities, cleaning and maintenance that with the flat-rate rental tax are instead “lost.”

For those who own just one apartment to rent out occasionally, the flat tax rate of 21% remains in most cases the most straightforward and convenient solution. The calculation is simple: on 10,000 euros of collected rent, the tax is 2,100 euros, regardless of the owner’s overall income. A taxpayer who declares, for example, 30,000 euros in short-term rental income, pays 7,300 euros in flat tax and does not modify their IRPEF income nor open a VAT registration.

From the second property onwards, however, the 26% rate begins to weigh. If you have two apartments with different incomes, it is advisable to apply the 21% rate to the one with the highest income: you can choose freely in your tax return. But if both apartments generate significant income, the overall tax burden grows substantially and it becomes prudent to evaluate alternatives.

Flat-rate regime with VAT registration: when it becomes the winning choice

Those who exceed the threshold of two properties, or who voluntarily decide to structure their activity in an entrepreneurial form, find themselves confronting the flat-rate regime. It is the preferential tax regime for individual businesses with annual revenues up to 85,000 euros, and for the short-term rental sector it presents particularly favorable characteristics.

The key mechanism is the profitability coefficient. For the relevant ATECO code, the profitability coefficient is 40%, which means that only 40% of revenues contributes to forming taxable income, while 60% is considered as an overall cost for conducting the activity. In simple terms: on 30,000 euros of income, the taxable income is only 12,000 euros.

On this reduced taxable base, two possible rates apply:

• 5% for the first five years of activity (startup rate, for those who have not conducted business activity in the three preceding years): with ATECO code 55.20.51 and coefficient 40%, the taxable income on 30,000 euros is 12,000 euros. With a 5% rate (startup), the substitute tax is 600 euros.
• 15% at standard rate, from the sixth year onwards: on the same taxable base of 12,000 euros, the substitute tax would be 1,800 euros.

To give an idea of the impact: in the flat-rate regime the substitute rate is 15%, reduced to 5% for the first five years, and applies only to 40% of revenues thanks to the profitability coefficient. This results in an effective tax rate of 2% of revenues in the first five years and 6% in subsequent years. Comparing: with flat tax at 21% you pay 21% on the entire revenue; with the standard flat-rate regime you pay 6% of the entire revenue; with the startup flat-rate you drop to 2%.

However, the flat-rate regime entails costs that the flat tax does not have. The main one is registration with the INPS Commercial Operators’ Fund: those who receive revenues through VAT registration with short-term rental activity do not pay ordinary fixed contributions, but only in proportion to the income produced. This specific relief for the short-term rental sector significantly reduces the weight of contributions. Contributions are always calculated on the same taxable base (40% of revenues) and those who adhere to this regime can request an additional 35% reduction on the total amount owed.

There are also additional obligations: electronic invoicing, periodic settlements (although simplified in the flat-rate regime), registration with the Chamber of Commerce, SCIA filing with the municipality, and updating of listings on platforms with the business profile.

A note on the ATECO code: a transition in progress

It is worth clarifying a topic that generates confusion among operators. The traditionally used ATECO code is “55.20.51 – Furnishing rooms for short stays, holiday homes and apartments, bed and breakfasts, residences”. Over time the classification has undergone updates that have introduced more specific distinctions by facility type; those who already have a VAT registration open with code 55.20.51 should verify with their accountant if and when to make any updates. In any case, the 40% profitability coefficient remains unchanged, which is the fiscally relevant data for calculating the tax in the flat-rate regime, regardless of the code applied.

“The 5% flat-rate regime is often the most advantageous choice overall, even surpassing the 21% flat tax. If with the 21% flat tax you keep 790 euros in your pocket from 1,000 euros, with the 5% flat-rate the net amount can rise to approximately 814 euros, net of taxes and contributions.”

— Laleggepertutti.it, comparative analysis of tax regimes for short-term rentals, March 2026

Three practical scenarios for Genoa property owners

Applying these principles to the Genoa context is useful because the local market has specific characteristics. According to data from the Liguria Regional Tourism Observatory, the AAUT (Furnished Apartments for Tourist Use) active in Liguria are 39,099, with an overall capacity of approximately 160,000 beds, a figure comparable to traditional accommodation facilities. In particular, in the Metropolitan City of Genoa, active AAUT number 11,569. A constantly growing tourist demand, therefore, which makes the Genoa market for short-term rentals particularly dynamic.

Let us look at three typical profiles of Genoa property owners and which regime best suits each:

Scenario A — The owner with a single apartment

A Genoa property owner rents their apartment in the historic center for a total of 180 days per year, collecting approximately 18,000 euros. This is the most common case: the vast majority of properties offered online belong to private owners, often with inherited homes put to income to prevent them from remaining unused. In this scenario, the 21% flat tax is the natural choice: no VAT registration, no mandatory accountant, tax of 3,780 euros on the entire income. Administrative simplicity has real value, especially for those who do not want to structure a professional activity.

Scenario B — The owner with two apartments

Those who manage two apartments in Genoa — perhaps one in Porto Antico and one in the caruggi — find themselves in a situation where the flat tax remains applicable, but with differentiated rates: 21% on the property generating higher income, 26% on the other. On a total income of 30,000 euros (e.g. 18,000 + 12,000), the overall tax would be 6,900 euros (3,780 + 3,120). In this scenario, it is already advisable to make a numerical comparison with the flat-rate regime: the flat-rate regime may be more convenient than private management with a 26% flat tax, but it depends on income, costs, location, management and future prospects. The optimal choice requires a personalized simulation with an accountant.

Scenario C — The owner with three or more apartments

From the third property onwards, a VAT number is no longer a choice but an obligation. Those who will manage three or more residential units must open a VAT number, facing more complex accounting obligations (electronic invoicing, VAT settlements, record keeping) and falling under the ordinary business tax regime. In this case, the flat-rate regime — if the requirements are met and revenues do not exceed 85,000 euros — often becomes the most efficient solution. Entrepreneurial tourist rental can also be chosen by those managing one or two properties, therefore without the regulatory obligation provided for those who own three or more. A property owner evaluating expanding their real estate portfolio in Genoa should plan to open a VAT number before reaching the third unit, to avoid retroactive tax reclassifications. Those close to the three-property threshold should consider the opportunity to open a VAT number so they can access the subsidized rate of 5% provided for new businesses, with significant tax savings for the first five years.

“Almost 4 million stays in short-term rentals from January to September [2025] is a figure that certainly cannot be overlooked: the short-term rental market is in constant growth and to date there are almost 40,000 short-term rental properties with approximately 160,000 beds, equivalent to traditional accommodation structures.”

— Luca Lombardi, Regional Tourism Assessor of Liguria (source: Regional Tourism Observatory of Liguria, November 2025)

The Genoa market context: why tax choice is more relevant today

Tourism demand in Genoa provides the context for reading these tax decisions. Data from the Regional Tourism Observatory of Liguria indicate that, in the January-September 2025 period, Ligurian short-term rentals registered almost 4 million stays, representing a significant share of the total regional tourism stays. The Genoa market remains solid and growing, with significant presence in the non-hotel segment.

At the national level, the picture is equally favorable: the non-hotel sector has recorded sustained growth in recent years, at a faster pace than the traditional hotel industry. The short-term rental market, despite regulatory pressure, remains attractive. In this scenario, the choice of tax regime is not purely an accounting matter: it directly impacts the net profitability of the investment and the competitiveness of the price offered to tourists.

A specific figure on the sector’s weight in Genoa province: the penetration of online short-term rentals in the province remains below the national average, with peaks in more touristy coastal locations such as Camogli and Portofino. The provincial residential stock is large and largely not intended for short-term rental, indicating potential supply still largely untapped.

Finally, an element regarding sector challenges: according to industry analyses, only a minority of owners possess three or more properties intended for short-term rentals, although this minority represents a disproportionate share of the listings published on platforms. The modification to the business threshold, therefore, directly impacts a numerically limited but not negligible minority of owners in terms of supply volume.

Practical implications: what to do today

2026 brought a regulatory discontinuity requiring property owners to make choices that were previously automatic. Below is an operational summary of the assessments to make based on your situation:

• I have a single apartment and don’t want to structure a business: the 21% flat tax remains the simplest and most convenient solution. Verify that you have the CIN (National Identification Code) updated, mandatory since November 2, 2024, for all structures intended for short-term rentals and tourist accommodation.
• I have two apartments: run a numerical simulation comparing the flat tax (21% + 26%) with the flat-rate regime. If total revenues exceed 20,000-25,000 euros and you plan to maintain the activity long-term, the flat-rate regime may already be convenient.
• I’m about to reach the third apartment: plan to open a VAT number preventatively to access the startup rate of 5%. Opening a VAT number entails being subject to the ordinary regime or the flat-rate regime, but also offers greater tools for deducting and detracting costs such as utilities, maintenance, cleaning services, agency commissions and advertising expenses.
• I manage several apartments through an operator: verify with your accountant whether the activity carried out by the manager (such as a property management company) impacts your tax qualification as owner; generally the taxation of the lessor and that of the manager remain separate.

In all cases, advance tax planning is essential to avoid errors, audits or unforeseen surcharges. The choice of regime is not reversible during the fiscal year: it must be made beforehand or at the time of opening the business.

If you are considering generating income from your property in Genoa and want to understand the market potential first — and only then address the tax choice with your trusted professional — you can manage your property with a professional operator who knows the specifics of the Genoa context. The first step is always informational.

Note: this article is for informational purposes and does not constitute tax advice. For decisions specific to your situation, consult an authorized accountant or tax consultant.