TRANSPARENCY OBLIGATIONS RELATED
TO THE RECEIPT OF PUBLIC RESOURCES
Associations, foundations and nonprofit organizations are required to publish on their websites or similar digital portals, by June 30 of each year, information on grants, subsidies, benefits, contributions or aid, whether in cash or in kind, not of a general nature and without consideration, remuneration or compensation”, to the same actually disbursed in the previous fiscal year by public administrations. By Circular n°. 6 of June 25, 2021, the Ministry of Labor and Social Policy clarified that “general character” should be understood to mean the benefits received by the beneficiary on the basis of a general regime, under which the subsidy is provided to all individuals who meet certain conditions.
RELATED TRANSPARENCY OBLIGATIONS
TO THE 5 PER THOUSAND
The regulations on the 5 per thousand are contained in Legislative Decree n°. 111/2017 and in the Dpcm of July 23, 2020. The recipients of the same are, for what is of interest here, Third Sector entities (Ets), scientific and health research entities, and amateur sports associations (Asd). The allocation of the share of 5 per thousand to third sector entities will only take place from the year 2022, the single national register of the third sector (Runts) having been operational since November 23, 2021. Until then, instead of Ets, the portion of the grant continues to be allocated to support “voluntary bodies,” a category that includes:
social promotion associations (SSAs), registered in national, regional and provincial registers.
TRANSPARENCY OBLIGATIONS RELATED TO CHARITABLE DISBURSEMENTS
On the subject of liberal disbursements, the decree of the Minister of Economy and Finance Feb. 3, 2021, stipulated for certain types of nonprofit entities the obligation to send to the Internal Revenue Service the notification of liberal disbursements received from both individuals and legal entities. Among the entities required to comply with this requirement are: – social promotion associations; The submission obligation for the entities just mentioned applies: – as of 2022 (with reference to the data of disbursements made in 2021), but only for entities that have recorded in their last financial statements revenues exceeding 1 million euros; – as of 2023 (with reference to the data of disbursements made in 2022), but only for entities that have recorded in their last financial statements revenues exceeding 220,000 euros.
