Capital Gains Tax in Italy: The 26% Rate for Shares and Quotas

What is the capital gains tax rate in Italy for shares and quotas?

The rate is 26%. It applies to any gain an individual realises from selling shares or quotas in a company, and it makes no difference whether the holding is qualified or not. This has been the position since 1 January 2019, and it is worth stating plainly, because a fair amount of content still written for this exact query implies otherwise.

The single current rate: 26% on any gain, qualified or not

Since 1 January 2019, gains on qualified holdings are declared in the same section of the tax return as non-qualified holdings and are taxed at the identical 26% substitute tax. The Agenzia delle Entrate's own Redditi PF 2026 instructions confirm this directly for Quadro RT, Sezione II: gains realised from 1 January 2019 go into that section precisely because they are now subject to the 26% imposta sostitutiva, not to a separate mechanism. Before that date, a qualified holding followed different rules entirely. That part is history now, not a live option, and the next section explains exactly why.

The rate itself was set by Art. 3 D.L. 66/2014, which raised the substitute tax on non-qualified-holding gains and related financial income to 26%, "wherever they occur", with effect from 1 July 2014. Four and a half years later, the same rate absorbed qualified holdings too, and that is the number in force today for every disposal of shares or quotas.

Why the rate is not 12.5%, even though the statute still prints it

Open the founding statute and you will still find "12,50 per cento" printed in Art. 5(2) D.Lgs. 461/1997. That figure was the 1997 original. It has not applied for over a decade. The rate rose to 20% in 2012, then to 26% from 1 July 2014, and 12.5% survives on the page only as a historical artefact of drafting, not as anything a seller today should apply. Anyone quoting 12.5% as the current Italian capital gains rate is quoting a repealed number. Treat it the way you would treat a superseded edition of a contract: interesting for context, useless for compliance.

Capital gains tax in Italy at a glance, by payer type

26% for an individual, 5% effectively taxable for a qualifying company, since 1 January 2019 the rate no longer depends on the size of the holding. Position as at 2026.

Has Italy abolished the qualified vs non-qualified rate distinction?

Yes, for the rate. Not for the classification itself. That is the distinction that trips people up, and it deserves its own section rather than a footnote, because it is the single biggest gap in how this topic is usually explained.

What "qualified" and "non-qualified" still mean, and what they no longer decide

A shareholding is still classified as qualified or non-qualified under Art. 67(1)(c) and (c-bis) TUIR, and that label still governs which section of Quadro RT the gain goes into. What it no longer governs is the rate. Before 2019, the label decided how much of the gain was taxable at all. Since 2019, both labels lead to the same flat 26%, applied to the whole gain either way.

The mechanism: Art. 68(3) TUIR, repealed by L. 205/2017

The change has a precise legal cause. Art. 68(3) TUIR, the rule that had set a reduced taxable base for qualified-holding gains, was repealed by Legge 27 December 2017, n. 205, the 2018 budget law. Normattiva's own AGGIORNAMENTO note on the article records it in four words: "COMMA ABROGATO DALLA L. 27 DICEMBRE 2017, N. 205." That single repeal is the entire mechanism behind today's unified rate. Few summaries trace it this far, which is exactly why it belongs on this page in full.

Before 2019: a percentage of the gain, not a flat rate, and only for qualified holdings

Before the repeal took effect, a qualified holding's gain was never taxed at a flat rate at all. Only a percentage of it entered the seller's ordinary taxable income, at progressive IRPEF rates: 40% of the gain for disposals before 1 January 2009, 49.72% from 1 January 2009 to 31 December 2017, and 58.14% for disposals in 2018, the final year of the old mechanism. These three figures are historical facts about the past, tied strictly to those date ranges, and they say nothing about a disposal happening today.

What makes a shareholding "qualified" in Italy?

The classification survives the 2019 reform even though the rate does not depend on it any more, and it still decides how a disposal is reported. Under Art. 67(1)(c) TUIR, the test runs on either voting rights or capital, and the threshold changes depending on whether the company is listed.

Listed companies: more than 2% of voting rights or 5% of capital

A holding in a company traded on a regulated market is qualified once it represents more than 2% of the voting rights exercisable at the ordinary shareholders' meeting, or more than 5% of capital. Either threshold on its own is enough.

Unlisted companies: more than 20% of voting rights or 25% of capital

For a company not traded on a regulated market, the bar sits higher: more than 20% of voting rights, or more than 25% of capital. Art. 67 TUIR sets both scales in the same paragraph, distinguishing only by whether the shares are negotiated on a regulated market.

Everything else is non-qualified

A disposal that does not cross either threshold falls under Art. 67(1)(c-bis) TUIR instead: every other gain from the onerous sale of shares or a participation in the capital or assets of a company, partnership or body. A founder selling a 10% stake in an unlisted Italian company, for instance, holds a non-qualified participation. The label still matters for the paperwork. It does not change what is owed.

How is the taxable gain calculated, and can a loss be carried forward?

Numbers only matter once you know what to plug into them, so this section walks through the computation itself.

The computation: sale proceeds minus acquisition cost

Under Art. 68(1) TUIR, the gain equals the price received for the shares minus the acquisition or construction cost, increased by any other cost genuinely inherent to the shareholding, such as incidental transaction costs. The formula applies the same way whether the holding is qualified or non-qualified: the 2019 reform changed the rate, not the arithmetic.

Losses carried forward up to the fourth following tax period

If aggregated losses exceed aggregated gains in a given tax period, the excess can be deducted from gains and other qualifying income in later tax periods, but never beyond the fourth. The condition is procedural and unforgiving: the loss has to be declared in the return for the tax period in which it was realised. Miss that filing, and the right to carry it forward is gone, regardless of how the loss itself arose.

Gains and losses on qualified and non-qualified holdings are now aggregated together

This aggregation is itself a direct consequence of the 2019 unification. Qualified and non-qualified holdings used to sit on separate tracks, each with its own rules for offsetting gains and losses. They now sit on one track, computed together, which is one more reason the qualified/non-qualified label has shrunk to a reporting distinction rather than a computational one.

How is the 26% tax actually paid?

Three mechanisms exist, and which one applies depends on how the shares are held, not on the size of the gain.

Self-assessment: declared in Quadro RT (the default)

By default, the individual reports the gain in Quadro RT of Modello Redditi PF and pays the 26% substitute tax together with the return. This is the regime the Agenzia delle Entrate's own instructions describe directly, and it is the one that applies unless an intermediary has been given a specific mandate to do otherwise.

The administered savings regime: the intermediary withholds gain by gain

Under Art. 6 D.Lgs. 461/1997, a taxpayer may opt for an authorised Italian intermediary holding the securities to apply the substitute tax on each realised gain as it happens. Opting in removes the need to report the gain separately in the individual's own return, since the tax has already been settled at source.

The managed savings regime: tax on the annual accrued result

Under Art. 7 D.Lgs. 461/1997, where portfolio management is entrusted to an authorised intermediary, the tax can instead be computed annually on the accrued result of the management, rather than gain by gain. The rate applied here is the same 26%, by the general mechanism of D.L. 66/2014. That said, this figure rests on the decree's broad "wherever they occur" wording rather than a dedicated Agenzia delle Entrate confirmation specific to Art. 7, so treat it as the logical extension of the general rule, not as a separately sourced rate.

Does an Italian company pay tax when it sells a shareholding? The participation exemption

Everything so far has covered an individual seller. A company selling a shareholding sits under an entirely different set of articles, built around what is usually called the participation exemption, or PEX.

95% of the gain is exempt from IRES

Under Art. 87 TUIR, a resident company's capital gain on a qualifying shareholding is 95% exempt from IRES. Only the remaining 5% enters taxable income. This is the corporate mirror of the individual's 26% rule, and it is a pairing that generalist content covering this exact search almost never makes, since the individual rate and the corporate exemption tend to live on separate pages elsewhere.

The four cumulative conditions

Qualifying for PEX requires meeting all four conditions at once, not just one or two of them:

1. continuous ownership from the first day of the twelfth month preceding the month of disposal, a 12-month minimum holding period, with later-acquired holdings treated as sold first;
2. classification among financial fixed assets in the first balance sheet closed during the holding period;
3. the investee's tax residence outside a privileged tax regime, under the Art. 47-bis(1) criteria, or proof of the Art. 47-bis(2)(b) condition;
4. the investee carrying on a genuine commercial activity, as defined by Art. 55 TUIR.

Why a real-estate holding company cannot use PEX

Condition four is treated as unmet where the investee's assets are predominantly non-instrumental real estate. A holding company built mainly around property fails the genuine-commercial-activity test by definition, and PEX simply does not reach it, whatever the other three conditions look like.

The timing tests behind conditions (c) and (d)

Both timing conditions run on a look-back, not just a snapshot at the moment of sale. Condition three runs continuously from the first period of ownership, though five periods are enough for a disposal outside the group of a relationship older than five periods. Condition four runs continuously from at least the beginning of the third period before the disposal. A holding structured only weeks before a sale, in other words, will not satisfy these look-backs no matter how the paperwork is drafted at closing.

What happens if a corporate gain does not qualify for the participation exemption?

Missing even one PEX condition changes the outcome completely, not partially.

Full IRES taxation on the whole gain

Under Art. 86 TUIR, a gain that fails any Art. 87 condition is taxed in full as ordinary business income within IRES. The computation is the sale price or indemnity received minus the un-amortised tax cost of the shareholding. IRES itself sits at 24% as at 2026, a rate detailed on corporate tax in Italy rather than re-derived here.

The optional five-period spread

Where the shareholding has been held at least three years, the company can elect, in the tax return for the year of realisation, to spread the gain over that year plus up to four more, in equal instalments. The election has to be made in the return itself. It cannot be added retroactively once the return has been filed, so this is a decision to make before submission, not after.

Does Italy tax a non-resident who sells shares in an Italian company?

The site's own audience is most likely to ask exactly this question, and generalist content handles it worst, usually by conflating it with real estate rules that do not apply here at all.

The default: Italy-sourced, taxable

As a rule, yes. Under Art. 23(1)(f) TUIR, a non-resident's gain on a shareholding in an Italian resident company is treated as Italy-sourced. That is the starting point for every non-resident seller, before any exception is considered.

The listed-share carve-out

A broad exception applies to listed shares. A gain on a non-qualified holding in a resident company traded on a regulated market is excluded from Italian sourcing altogether, however it is held. That exclusion holds regardless of any tax treaty, because the gain is simply outside Italian sourcing in the first place, not merely relieved by a bilateral agreement.

The white-list exemption for an unlisted non-qualified holding

A second, narrower exemption covers unlisted holdings. Under Art. 5(5)(a) D.Lgs. 461/1997, gains and losses on a non-qualified holding are exempt if the seller is resident in a state with an adequate exchange of information with Italy, the so-called white list. This exemption sits alongside a non-resident's broader personal tax exposure in Italy, which covers considerably more ground than capital gains alone.

A qualified holding sold by a non-resident: the domestic default stands

No equivalent domestic exemption covers a qualified holding sold by a non-resident. The Italy-sourced default from Art. 23(1)(f) TUIR applies in full, and a tax treaty between Italy and the seller's country of residence may reallocate the taxing right. No specific treaty article or percentage is asserted here: the general possibility of treaty relief exists, and the specific outcome depends on the treaty in question, which is a conversation for an adviser rather than a blanket figure on this page.

How did Italy get from a 12.5% rate to today's 26%? The reform timeline

Every rate above rests on a chain of statutes stretching back to 1997. Almost nothing written about this topic online traces that chain end to end, which is exactly what this section does.

State the current rate first: 26%, since 2019, for every shareholding. Everything above is how it got there. Position as at 2026.

1997 to 2014: from 12.5% to 26%, for non-qualified holdings

The imposta sostitutiva began life at 12.5% in 1997, under D.Lgs. 461/1997. It rose to 20% in 2012, and then, under D.L. 66/2014, to 26% from 1 July 2014. Both 12.5% and 20% are context, not current figures. Neither applies to a disposal happening today.

2009 to 2018: a shrinking share of a qualified holding's gain

For qualified holdings specifically, the same 2009-to-2018 window followed a different logic entirely: not a rate at all, but a rising percentage of the gain brought into ordinary progressive taxation, from 40% before 2009 to 49.72% in the middle years to 58.14% in the final year of the old mechanism.

2017 to 2019: the repeal that unified the rate

The two tracks converge with the repeal of Art. 68(3) TUIR by L. 205/2017, effective for disposals from 1 January 2019. From that date, both kinds of holding sit under the same 26% rate, and the chain that started in 1997 ends, for now, at the number quoted at the top of this page.

What does this page not cover?

A page about capital gains tax has to say, plainly, where its own coverage stops. Otherwise a reader assumes silence means agreement.

Real estate and cryptoasset gains

Real estate capital gains fall under a separate provision of the TUIR, outside Art. 67(1)(c) and (c-bis), and were not researched for this page. Cryptoasset taxation is a distinct, separately evolving regime in Italian law. Neither figure appears anywhere on this page, in any form, and neither should be inferred from anything written above.

The flat-tax regime for new residents: a partial carve-out only

Gains on qualified holdings realised in the first five tax periods of the neo residenti option remain under the ordinary rules described on this page, not under the flat-tax option's lump sum. The carve-out names only qualified holdings; gains on non-qualified holdings are not excluded by this provision. The regime itself, on the merits, belongs on its own page.

Corporate tax residence and esterovestizione

Whether a company counts as tax-resident in Italy at all is a separate question, governed by its own tests and its own risk of esterovestizione, and it is not answered here. For how we handle incorporation, including the steps that follow once a structure is settled, our team can walk through the specifics on a call.

Frequently asked questions about capital gains tax in Italy

From our practice

A few patterns recur often enough to be worth naming plainly, rather than leaving founders to discover them mid-transaction.

The twelve-month PEX holding period is measured from the first day of the twelfth month before disposal, not counted backwards in round numbers from the closing date. A holding that misses this test by a matter of weeks loses the exemption entirely, not partially, which makes it a recurring and entirely avoidable trap. The classification as a financial fixed asset has to happen in the first balance sheet closed during the holding period. Adjusting the classification later, once a sale is already being negotiated, does not satisfy the condition retroactively. And individuals using the administered savings regime sometimes still declare the same gain a second time in Quadro RT, out of caution, without realising the intermediary has already settled the tax at source.

None of these are exotic situations. They are the ordinary mechanics of a disposal, and getting the timing and the paperwork right, well before a transaction closes, matters more than any single rate figure on this page.

The rates and thresholds above are given per the versions in force as at the update date. Applying them to a specific disposal should be checked with an adviser.