Stama describes the imposition of the annual fee of 600 euros per accommodation on short-term rental companies as irrational and illegal.
Specifically, in a statement it said:
Taxes go down… but for others they go up
While the government abolishes the memorandum tax for natural persons and talks about extending the abolition to legal entities, an entire industry is being led to a new, targeted burden.
Article 248 of the draft law ‘National Customs Code and Other Provisions‘ imposes a fee of EUR 600 per property on short-term rental property management companies, through the classification of their accommodation as branches. This is a technically incorrect and administratively unfair option, which:
- Bypasses the concept of a branch as defined by law.
- It directly contradicts the judgment of the Council of State, which in its decision 602/2025 ruled – by a majority (5-2) – in favour of the annulment of Circular E. 2024 /09-04-2024, with binding reasons, even if not final.
- It overlooked the fact that accommodation establishments by law do not have staff, nor do they provide services other than the legal obligation to provide bed linen.
Injustice and unequal treatment within the same market
The new regulation creates a discrete and selective burden regime, as:
- No similar fee is imposed on other companies that manage properties, such as real estate agencies or condominium and common property collection managers.
- It affects businesses only because they are active in the short-term rental sector.
- Instead of recognising the nature of short-term leasing as a modern and decentralised business model, an interpretation is chosen that turns it into a ‘tax target’. Accommodation management is not a dispersal of branches – it is a single service, organised centrally and without on-site activity.
There is still time – Let logic and equality prevail
The new fee introduced by Article 248 is not just a tax burden, but an institutional contradiction, since it contradicts established case law and the very nature of the sector.
We request:
- The immediate withdrawal or substantial amendment of the article.
- The application of uniform and transparent rules for all property management professionals.
- Respecting the jurisprudence of the CoE, which has already taken a clear position or waiting for the final ruling in December.
Professionals in the sector are calling for equal treatment. Given that the measure has not yet been implemented, there is scope for reassessment.
