The Revenue Agency has issued a substantial circular (7/E) on deductible / deductible charges.
From a first reading of the paragraphs relating to the insurance world, it seems that some points of interest can be drawn.
Traceability and traceability to the payment contractor. The Circular on page 31 (General aspects) he claims “To about, it is believed that the charge can be considered borne by the taxpayer to whom the expense document is made out, not noting the material executor of the payment for this purpose, the latter aspect concerning the internal relations between the parties. The payment, indeed, it can also be made through payment systems “traceable” in the name of another person, also not fiscally dependent, provided that the charge is actually borne by the taxpayer holder of the expense document. It can, for example, verify that the taxpayer uses the debit or credit card in the name of the child to pay the deductible expenses related to himself, for which there is an obligation of traceability, without losing the right to deduct, provided that this charge is actually borne by the holder of the expense document. This circumstance can also be supported by the taxpayer's declaration who reports that he has reimbursed the child, cash, the expenditure incurred.
The taxpayer could also use their credit card to pay for deductible expenses related to the spouse, for which there is an obligation of traceability, without losing the right to deduct, provided that this charge is actually borne by the holder of the expense document. This circumstance can be supported by the joint name of the current account on which the credit card is issued.”
Based on this statement, it seems that the Company, when sending the certificates of the premiums paid, is relieved of the burden of ascertaining whether the payment, traced, comes from an account / instrument in the name of the contractor, without prejudice to the existence of the contractor-payer flag in communications to the Tax Registry.
Policies taken out by banks. The Agency (pag. 195) reiterates that the premiums of policies taken out by a bank in the name and on behalf of the employee (perhaps, more correctly, in its own name but on behalf of third parties) they are deductible by the insured subscriber. The statement is resumed a few lines later with reference to the policies taken out by a bank on behalf of the borrowers. This contrasts with the assessments on insurance tax relating to employment risk policies, where the same Agency seems to believe that the collective policy stipulated by the bank is contracted on its behalf and not on behalf of the borrowers.
Natural disaster policies and credit transfer from sismabonus. Partially resolving the doubts raised by the operators, the Agency (pag. 232) states that premiums are deductible to 90% if related to a policy stipulated by 01.07.2020. There does not seem to be any limitations for the premiums relating to subsequent annuities with respect to the assignment of the credit. With reference to the identity of the purchasing company, the credit from sismabonus writes the circular “[…] for insurance premiums paid to an insurance company to which the tax credit of the deduction of the 110 percent due for carrying out anti-seismic interventions […]”. It would therefore appear that, for the Agency, the company acquiring the credit must coincide with the one contracting the policy for disasters, although the norm does not seem to impose it. The confusion increases if you read a few lines over a page 232 the sentence of the paragraph “limits of deductibility” which states “The deduction from gross tax for premiums for the risk of disasters for insurance stipulated at the same time as the transfer of the tax credit relating to the bonus earthquake 110 per cent to an insurance company is entirely due to the holders of total income up to euro 120.000“, where the indefinite article again suggests the non-mandatory coincidence between the contracting company and the purchasing company.