First Home Relief and Purchase of Multiple Properties: Conditions Outlined by Supreme Court Order No. 15422/2025

The purchase of a first home represents a fundamental step for many, and to facilitate this important investment, the legislator has provided specific tax reliefs. However, situations are not always straightforward, especially when one decides to purchase multiple real estate units with the intention of merging them into a single dwelling. It is precisely on this delicate balance that the Court of Cassation has ruled with Order No. 15422 of June 10, 2025, providing essential clarifications for taxpayers and industry professionals.

The Issue of Multiple Purchases and First Home Relief

The tax benefit related to the purchase of a "first home" is a cornerstone of our tax system, aimed at incentivizing access to property ownership. The legislation provides for significant reductions in taxes (registration, mortgage, and cadastral) for those who purchase a dwelling that meets certain requirements. But what happens when a buyer decides to purchase, simultaneously, not one but multiple real estate units, with the intention of merging them into a single dwelling? Practice and case law have often debated this point, seeking to reconcile the relief purpose with the need to prevent abuse.

The Court of Cassation, with the ruling under examination, has reiterated a fundamental principle that clarifies any doubt. In the specific case, the dispute pitted D. D'A. against the financial administration, with the Regional Tax Commission of L'Aquila having rejected D. D'A.'s appeal. The Supreme Court confirmed the orientation already expressed in previous rulings (such as No. 10011 of 2009), precisely outlining the conditions for accessing the relief.

"First home" relief - Purchase of multiple real estate units - Conditions - Single non-luxury residential unit - Necessity - Deadline for unification - Maximum limit of tax audits - Applicability. In terms of tax reliefs, benefits for the purchase of a "first home" are also recognized in the presence of the simultaneous purchase of multiple real estate units to be used as a single non-luxury residential unit and presuppose the effective occurrence of such unification within the three-year period granted to the financial administration for conducting audits, beyond which it would no longer be possible.

This summary is of extreme importance. It clearly states that the "first home" relief can also be extended to those who purchase multiple real estate units simultaneously, provided that these are intended to become a single dwelling and that this dwelling does not fall into the category of "luxury homes." The crucial point is that the physical and cadastral unification of the real estate units must actually occur. But not only that: the Cassation Court sets a very precise time limit for this unification.

The Crucial Role of Unification and Audit Deadlines

Order No. 15422/2025 emphasizes that the effective unification of real estate units into a single non-luxury dwelling is an essential condition for maintaining the tax relief. This unification cannot be a mere intention but must materialize within a specific period. The Court identifies this deadline as the three-year period granted to the financial administration for conducting audits. This deadline is established by Article 76 of Presidential Decree of April 26, 1986, No. 131, the Consolidated Text of provisions concerning registration tax, which governs the terms for the assessment and rectification of acts.

This means that the taxpayer intending to benefit from the "first home" relief by purchasing multiple properties to be unified must ensure that the merging works and related cadastral procedures are completed within three years from the date of registration of the purchase deed. Beyond this deadline, the financial administration would no longer have the possibility to verify the effective realization of the unification and, consequently, the relief could be revoked with the application of penalties.

• Simultaneous Purchase: It is permissible to purchase multiple real estate units.
• Single Destination: The units must be intended to form a single dwelling.
• Non-Luxury: The dwelling resulting from the unification must not fall into luxury cadastral categories.
• Effective Unification: Physical and cadastral merging must actually occur.
• Three-Year Deadline: Unification must be completed within the three-year period granted to the financial administration for audits.

It is essential that the taxpayer is aware of these deadlines and acts promptly, possibly availing themselves of the advice of professionals (engineers, architects, surveyors) for the design and execution of the works, and legal and tax consultants for the correct management of administrative and tax procedures.

Conclusions and Practical Implications

The Court of Cassation's Order No. 15422/2025 offers an important confirmation and a warning for those preparing to buy a home. While on the one hand, it reiterates the possibility of benefiting from the "first home" relief even in cases of multiple purchases, on the other hand, it strongly emphasizes the need for concrete and timely unification of the real estate units. The clarity of this ruling is crucial to avoid disputes with the Tax Authority and to ensure the correct application of relief provisions. Taxpayers must carefully plan the operation, taking into account not only the purchase but also the technical and bureaucratic times required for unification. A proactive and informed approach is key to fully benefiting from tax reliefs without encountering unpleasant surprises.