Corporate Tax in Italy: IRES, IRAP and the 2026 Filing Calendar

What corporate taxes does a company pay in Italy?

Two taxes reach company profit, one national and one regional, and the Agenzia delle Entrate (Italian Revenue Agency) administers both and publishes the annual instructions in which the rates in force appear. IVA falls on turnover rather than profit and stays off this page.

IRES: the 24% national corporate income tax

IRES, or imposta sul reddito delle società (corporate income tax), is charged at 24%, stated in one line by the regulator on its Agenzia delle Entrate: IRES page. One rate, no bands, no municipal layer on top. Its base is reddito complessivo (total taxable income), which starts from the accounting result and is then adjusted under the TUIR, the Testo unico delle imposte sui redditi (Consolidated Income Tax Act). Companies declare it on the Redditi SC form.

IRAP: the 3.9% regional tax on net production value

IRAP, or imposta regionale sulle attività produttive (regional tax on productive activities), is charged at a standard 3.9% on valore della produzione netta (net value of production), as the Agenzia delle Entrate: istruzioni IRAP 2026 state. One clarification matters more than the figure: IRAP is not a surcharge on IRES. Different level of government, different base, a separate return, a rate the region can move. A company with a thin margin and a large fixed-term payroll can owe real IRAP in a year when its IRES is near zero.

Italian company tax rates in 2026, at a glance

Every corporate-level rate in force for 2026 sits below with its base and its rule. The values for financial intermediaries and insurers follow the Agenzia's 2026 instructions rather than the printed statute, for the reason set out further down.

Where VAT and personal taxes sit, and why they are not on this page

IVA, Italian VAT, runs at 22% with reduced rates of 4%, 5% and 10% (Art. 16 D.P.R. 633/1972). Turnover tax, not profit tax, and everything on the VAT number is covered separately. Personal regimes for individuals who move to Italy form a third layer, with their own conditions and their own pages.

Why 27.9% is not Italy's effective corporate tax rate

Comparison tables put Italy at 27.9% and stop there. The arithmetic is sound: 24 plus 3.9 is 27.9. The label is not, because the two rates apply to two different amounts of money, and no Italian authority publishes 27.9% as a rate.

Two statutory rates, two different tax bases

24% IRES and 3.9% IRAP are two separate taxes on two different tax bases. Adding them gives 27.9% as a headline figure, not as an effective rate on accounting profit. Useful for a first glance across borders, useless in a budget model: the second base comes from a narrower part of the income statement and leaves out cost lines the first deducts in full.

How the IRES base is built (Art. 83 TUIR)

Total income for IRES starts from the profit or loss shown in the income statement for the period, to which the increasing and decreasing adjustments prescribed by the TUIR are applied (Normattiva: TUIR, Art. 83). Accounting result first, tax adjustments second. Staff costs, interest within the ceiling described below and part of the IRAP paid all reduce this base.

What the IRAP base leaves out (Art. 5 D.Lgs. 446/1997)

IRAP takes a narrower slice of the same statement. Its base is the difference between the value and the costs of production under letters A) and B) of article 2425 of the Civil Code, excluding items 9), 10) letters c) and d), 12) and 13), and excluding extraordinary components arising from the transfer of a business. Item 9) is staff costs, so staff costs do not leave the IRAP base by that route. Items 10 c), 10 d), 12) and 13) are write-downs and provisions. The interest element of lease payments is not deductible either.

Cuneo fiscale: the full deduction for permanent staff

One deduction reverses most of that. Art. 11(4-octies) D.Lgs. 446/1997 allows the full deduction of the total cost of staff on open-ended contracts, the relief known as the cuneo fiscale (the labour cost deduction). Put plainly: IRAP bites on fixed-term contracts, on contractors and on interest, not on the permanent headcount. Two companies with identical profit and an identical wage bill can owe very different IRAP.

What this means for your own cost structure

Direction of travel depends on how a company buys labour and capital. For a labour-intensive business staffed on permanent contracts the real burden sits closer to the IRES rate alone, because the largest cost line leaves the IRAP base entirely. For a business running on fixed-term staff, contractors and debt it can climb above 27.9%, since those costs stay in the IRAP base after reducing the IRES base. The arithmetic breaks from the other end too: IRAP returns as a deduction against income tax, a flat 10% of the regional tax under Art. 6(1) D.L. 185/2008 plus the IRAP attributable to staff costs in full under Art. 2(1) D.L. 201/2011.

Who pays Italian corporate tax, and when is a company tax resident?

Two questions come before any rate for a foreign founder: whether IRES reaches the company at all, and whether IRAP reaches it separately. Residence settles the first, a three-month test the second.

The list of IRES taxpayers

IRES taxpayers fall into three groups on the Agenzia's own list: resident capital companies, that is S.p.A., S.a.p.a., S.r.l., cooperatives and mutual insurance companies, with SEs and SCEs resident in Italy; resident public and private bodies, including consortia, trusts and collective investment undertakings; and companies and bodies of any type not resident in Italy, taxable on income produced in Italy alone.

Three alternative residence tests, and one is enough

Since the D.Lgs. 209/2023 reform a company is resident if, for the greater part of the tax period, it has in Italy any one of three things: its sede legale (registered office), its sede di direzione effettiva (place of effective management), or its gestione ordinaria in via principale (ordinary management carried on principally there). Art. 73(3) TUIR frames the three as alternatives, so one is enough to make the company Italian for tax and pull its worldwide profit into the IRES base. A company incorporated abroad but run from an Italian desk meets the second or third test while failing the first, which is where residence disputes start.

A non-resident company: Italian-source income only

A foreign parent does not become an IRES taxpayer on its whole profit merely because it owns an Italian subsidiary: non-resident companies and bodies are taxed on income produced in Italy and on nothing else. The parent meets the Italian system again when the dividend is paid, through withholding rather than IRES.

The three-month IRAP threshold for non-residents

IRAP carries a presence test of its own. Under Art. 12(2) D.Lgs. 446/1997 production value counts as produced in a region only where the activity was carried on there for at least three months through a permanent establishment, a fixed base or an office. Below three months no IRAP arises there, so a short project can produce Italian-source income for IRES and no IRAP at all.

The società di comodo surcharge of 10.5 points

Status can add to the rate. A company classified as a società di comodo (a shell or dormant company) pays IRES with a surcharge of 10.5 percentage points, under Art. 2, commi 36-quinquies to 36-novies D.L. 138/2011. Attribute of the taxpayer rather than of the tax, and paid on the ordinary calendar.

How are the rates set, and what changed for 2026?

Rates are set on three levels: the statute fixes the standard figure, the administrator publishes the values in force each year, and the region moves the IRAP rate within a band. Two surcharges landed on top for 2026.

Sector IRAP rates: 4.20%, 4.65% and 5.90%

Three sector rates replace the standard 3.9% under the Agenzia's 2026 IRAP instructions: 4.20% for concession holders other than builders and operators of motorways and tunnels, 4.65% for financial intermediaries and other financial entities, and 5.90% for insurance undertakings. Anyone checking those against Normattiva: D.Lgs. 446/1997, Art. 16 will read different figures in the printed comma 1-bis; we publish the Agenzia's values, and the next section explains why.

Regional variation of 0.92 points, in both directions

Regions set the rate that actually applies. Art. 16(3) D.Lgs. 446/1997 lets each region vary the rates by up to 0.92 percentage points and differentiate by sector and by category of taxpayer, and since 2013 an ordinary-statute region may reduce IRAP as far as zero by its own law. Variation runs both ways, so calling the regional layer a surcharge misreads it. We publish no figures for individual regions, because the official regional table was not accessible when this page was verified: check the region of registration.

The 2026 surcharges: banks, insurers and listed ATECO codes

Two increases arrived for 2026, each worth two percentage points. Art. 1, comma 74 L. 199/2025 raises the bank and insurance rates in Art. 16(1-bis)(b) and (c) by 2 points for the tax period following the one current at 31 December 2025 and the two after it, with a deduction of EUR 90 000 in the two later periods up to the additional tax. Art. 3(1) D.L. 21/2026 adds 2 points to the rates in Art. 16(1) and (1-bis) for two tax periods, for taxpayers whose predominant activity falls within the ATECO codes in Table 1 to that decree. For the sectors caught by that table the standard 2026 rate is therefore 5.9%, not 3.9%. We do not reproduce the codes, so check your own prevailing code.

The 20% IRES rate that lasted one tax period

A reduced IRES rate of 20% did exist, for one tax period only: the period following the one current at 31 December 2024, which for calendar-year taxpayers means 2025. Art. 1, commi 436-444 L. 207/2024 made it conditional on all of the following holding at once:

1. at least 80% of the 2024 profit placed in a special reserve;
2. at least 30% of that retained profit, and in any event at least 24% of the 2023 profit and at least EUR 20 000, invested in new Transizione 4.0 or Transizione 5.0 assets at production sites in Italy;
3. the number of labour units in 2025 not falling below the average of the previous three years;
4. permanent hiring producing employment growth of at least 1% over the period current at 31 December 2024;
5. no recourse to cassa integrazione guadagni, the state wage supplement scheme.

The procedure came from the ministerial decree of 8 August 2025 and the F24 codes from risoluzione n. 57 of 17 October 2025. A separate claim circulates in English-language write-ups, that newly established Italian companies enjoy a permanently reduced corporate rate; the Agenzia's IRES page carries no such rate.

Why the printed law text shows different rates than the ones in force

Check the numbers here against Normattiva and several will not match, and neither source is wrong. Normattiva publishes the original text of an article and carries later amendments in an AGGIORNAMENTO block of notes further down the page, while the operational rates come from the administrator's annual instructions to the return.

IRAP: the statute prints 3.50%, the rate is 3.9%

Art. 16, comma 1 D.Lgs. 446/1997 still prints 3.50 per cento. The reduction behind that figure came from D.L. 66/2014 and was repealed by Art. 1, comma 22 L. 190/2014, and the printed text was never restored. The rate in force is 3.9%, as the Agenzia's IRAP 2026 instructions state.

Sector rates: 4.20 and 5.30 in the text, 4.65 and 5.90 in the instructions

Same pattern one level down. The printed Art. 16(1-bis) gives 4.20% for banks and financial intermediaries and 5.30% for insurers; the IRAP 2026 instructions give 4.65% and 5.90%. Our table carries the instructions' values, because the administrator publishes each year the figures on which it will assess.

Dividends: the text says 27, the fraction 11/26 says 26

Art. 27, comma 3 D.P.R. 600/1973 reads 27 per cento in the printed version. The same comma grants non-residents a refund of up to eleven twenty-sixths of the withholding for foreign tax definitively paid on the same profit, and a fraction with 26 as its denominator can only have been written for a 26% rate, the one introduced by Art. 3 D.L. 66/2014. Comma 1 states 26% expressly.

The parent-subsidiary threshold sits in a note, not in the article

The participation threshold for relief under the parent-subsidiary regime is 10%, and the printed body of Art. 27-bis(1) is not where a reader finds it. The threshold in force was set by Art. 2, comma 2 D.Lgs. 49/2007 for profits distributed from 1 January 2009, and it lives in the AGGIORNAMENTO notes below the article.

How to read Normattiva without getting the number wrong

Two habits remove the problem. For any numeric threshold, open the AGGIORNAMENTO block at the foot of the document and read the notes attached to the comma in question: amendments live there, not in the body. For rates, take the operational value from the Agenzia's annual instructions to the return. Skip both steps and an outdated rate goes out in good faith, with a primary source apparently behind it.

What is the Italian corporate tax calendar for 2026?

Four dates matter in an Italian tax year and they run on two tracks. Filing has one deadline; payment has three points, one of which moves for taxpayers inside the ISA regime. The dates below assume a financial year closed on 31 December 2025.

Filing window: 15 April to 2 November 2026

Redditi SC is filed from 15 April until the last day of the tenth month after the tax period ends. For FY2025 that gives 2 November 2026, because 31 October 2026 falls on a Saturday and a deadline landing on a Saturday or a public holiday moves to the first working day (Agenzia delle Entrate: Redditi SC 2026). The IRAP return runs to the same deadlines under Art. 2(3) D.P.R. 322/1998, and taxpayers not required to file an income tax return file the IRAP return on that same date.

Balance and first advance: 30 June 2026

Payments open before the return is filed, which surprises most arrivals from another system. The balance for FY2025 and the first advance for 2026 fall due on the last day of the sixth month after the period closes, so 30 June 2026 for a calendar year, or within the following 30 days with an add-on of 0.40% by way of compensatory interest (Agenzia delle Entrate: versamenti delle imposte sui redditi).

The ISA deferral to 20 July 2026, and the 0.80% add-on

Taxpayers inside the indici sintetici di affidabilità fiscale (ISA, the synthetic tax-reliability indices) get a longer run. Those obliged to pay by 30 June 2026 on their income tax, IRAP and IVA returns may pay by 20 July 2026 with no add-on, or within the following 30 days with an add-on of 0.80%, under Art. 6 D.L. 89/2026. Read that second figure carefully: the add-on on this deferral is 0.80%, not the 0.40% of the ordinary extension.

The second advance on 30 November 2026, and how the advance splits

The advance equals 100% of the tax, in two instalments: 40% at the first payment date and the remaining 60% by the last day of the eleventh month after the period closes, 30 November 2026 for a calendar year. ISA taxpayers split it 50% and 50%. A single payment replaces the two where the first instalment would not exceed EUR 103. IRAP follows the same rules at 100%, and for IRES taxpayers the advance obligation arises above EUR 20.66.

Entratel, Fisconline and form F24

Returns travel through the Agenzia's electronic services, Entratel or Fisconline, with access by SPID, CIE, CNS or Entratel credentials, and payments go on the modello F24 (the universal form for paying taxes and contributions), as Agenzia delle Entrate: quando presentare la dichiarazione IRES sets out. One further filing shares the year: the annual IVA return goes in electronically between 1 February and 30 April.

Non-calendar years, and the balance sheet approval trap

Approving the accounts late buys no time on the return: only the closing date of the tax period fixes the filing deadline. Payment works the other way round. Where the law requires approval more than four months after year end, the balance and the first advance move to the last day of the month following approval, and where the accounts are not approved within the period set, to the last day of the month following its expiry. For IRAP the outer approval limit is 180 days from year end. For a year that does not close on 31 December, count months rather than copying dates: filing in the 10th month, balance and first advance in the 6th, second advance in the 11th.

How is the IRES base reduced before the rate applies?

Rate times accounting profit is not the calculation. Before 24% touches anything the base absorbs earlier losses, a ceiling on interest and part of the IRAP paid. Four rules do most of that work, and three reward planning done in advance.

Loss carry-forward: unlimited in time, capped at 80% a year

Losses carry forward with no time limit, and in each later year they may absorb up to 80% of taxable income (Normattiva: TUIR, Art. 84). A loss booked in year one is still usable in year nine. The cap has a practical edge: a profitable year always leaves at least a fifth of its income exposed, so a company coming out of losses pays IRES before those losses run out.

The first three years carry losses without the 80% cap

Start-up losses are treated better. Art. 84(2) TUIR lets losses from the first three tax periods from the date of incorporation be carried forward against the full taxable income of each later year, without the 80% cap, provided they relate to a new productive activity. For a foreign founder building a subsidiary that will lose money first, the qualifying window is fixed by the date of incorporation and does not reopen.

Interest deduction capped at 30% of ROL

Debt funding is deductible up to a ceiling. Under Art. 96(2) TUIR the excess of interest expense over interest income is deductible within 30% of the risultato operativo lordo (ROL, the gross operating result) of the period, plus 30% of the ROL carried over from previous periods. Thin-margin companies funded by shareholder loans reach it first.

IRAP comes back into the IRES base, twice

Part of the IRAP paid reduces the IRES base by two separate routes: a flat 10% of the regional tax under Art. 6(1) D.L. 185/2008, and the IRAP attributable to staff costs in full, from the tax period current at 31 December 2012 onwards, under Art. 2(1) D.L. 201/2011. Which closes the 27.9% argument from the other side. Part of the second tax reduces the first, so the two rates cannot be lined up and applied to a single number.

What is withheld when profit leaves Italy?

Corporate tax is not the end of the chain for a foreign owner. Profit taxed at company level is taxed again when it is distributed abroad, and the rate turns on who receives it. Four outcomes exist for dividends paid to a non-resident:

1. 26%, the baseline final withholding on dividends to a non-resident shareholder (Art. 27(1) and 27(3) D.P.R. 600/1973).
2. 1.20% for companies and bodies subject to corporate income tax in an EU member state or a listed EEA state and resident there (Art. 27(3-ter)).
3. 11% for EU and EEA pension funds and PEPP sub-accounts (Art. 27(3)).
4. 0% for qualifying foreign EU and EEA collective investment undertakings (Art. 27(3)).

The 26% baseline on dividends to a non-resident shareholder

26% is the starting point, and it is a ritenuta a titolo d'imposta (a final withholding), so nothing further falls due in Italy on that income. The same comma allows a non-resident recipient a refund of up to eleven twenty-sixths of the withholding for foreign tax definitively paid on the same profit. Anyone who reads a different percentage in the printed article should go back to the section on why text and rate diverge.

1.20% for EU and EEA corporate shareholders

A reduced final withholding of 1.20% applies to companies and bodies subject to corporate income tax in an EU member state, or in a listed EEA state, and resident there, on holdings not connected with an Italian permanent establishment (Art. 27(3-ter) D.P.R. 600/1973). That comma was amended with effect from 1 January 2026 by D.L. 27 March 2026 n. 38, converted with amendments by L. 22 May 2026 n. 88, so older descriptions need checking against the current text.

11% for EU and EEA pension funds, no withholding for UCITS

Two institutional categories sit lower still. EU and EEA pension funds, including PEPP sub-accounts, suffer withholding at 11%. No withholding applies to profits paid to foreign collective investment undertakings established in the EU or the EEA that comply with Directive 2009/65/EC, or whose manager is supervised under the AIFMD framework and established in a state with an adequate exchange of information.

Royalties, services and equipment rental: a final 30%

Dividends are not the only flow leaving an Italian company. Royalties paid to non-residents carry a final withholding of 30% on the taxable portion of the payment (Art. 25(4) D.P.R. 600/1973). The same 30% applies to amounts paid for the use of industrial, commercial or scientific equipment located in Italy, and, under the second comma of that article, to fees paid to non-residents for self-employed work and business services, including services supplied in the course of a business. Services rendered abroad fall outside, as do payments to Italian permanent establishments of non-residents. Interest and royalties between qualifying associated companies in different member states can be exempted under Art. 26-quater D.P.R. 600/1973, on that article's conditions. We give no figure for the taxable portion of a royalty, because Art. 25 does not define it.

Can an EU parent company recover the Italian withholding tax?

Withholding is not always final. An EU parent that meets the parent-subsidiary conditions can recover the Italian tax after the event, or arrange for it not to be withheld at all. Art. 27-bis D.P.R. 600/1973 carries both routes, and no result in the English-language top for this query mentions the article.

A direct holding of at least 10%, held for at least one year

Two numbers open the door: a direct holding of not less than 10% of the capital of the distributing company, held continuously for at least one year. The 10% figure was set by Art. 2, comma 2 D.Lgs. 49/2007 for profits distributed from 1 January 2009, and it is the threshold in force under Normattiva: D.P.R. 600/1973, Art. 27-bis. The refund is granted on application, never automatically.

The four cumulative conditions

Four conditions apply together, and failing any one closes the route:

1. a legal form listed in the annex to Directive 435/90/EEC;
2. tax residence in an EU member state, without being treated as resident outside the EU under a treaty with a third country;
3. subjection, in the state of residence, to one of the taxes listed in the Directive, with no optional or exempting regime unlimited in territory or in time;
4. a continuous holding of the participation for at least one year.

Documents: a foreign certificate plus your own declaration

Two documents carry the claim. A certificate from the competent tax authorities of the foreign state confirms conditions (a), (b) and (c); a declaration by the recipient company itself covers condition (d), the holding period. The certificate is usually the slow half, so the request goes in before the distribution reaches a shareholders' agenda.

Exemption at source instead of a refund

Refunds take time; not withholding takes none. On the application of the company receiving the dividends, the withholding agent may refrain from withholding altogether, provided the documents required by comma 2 are obtained before the date the profit is paid and kept until the tax assessment periods expire (Art. 27-bis(3)). Sequence decides the route: documents in hand before payment give exemption at source, the same documents a week later leave only the refund.

Anti-abuse, and treaty relief as the alternative route

Relief is not unconditional. Directive (EU) 2015/121 is implemented through Art. 10-bis L. 212/2000, the general anti-abuse rule, so an arrangement built mainly to capture the exemption can be disregarded. Where the parent-subsidiary route is unavailable a treaty may still cut the rate, and the forms for claiming treaty relief and refunds are published by the Agenzia delle Entrate: convenzioni contro le doppie imposizioni.

Which reliefs legally reduce an Italian company's tax bill?

Three provisions do most of the lawful reduction for a holding or an IP company, and none appears in the pages that answer this query with a single rate. Each carries a condition to satisfy before the transaction, not after.

Participation exemption: 95% of qualifying capital gains

Capital gains on qualifying shareholdings are exempt for 95% under Normattiva: TUIR, Art. 87. Four conditions must hold together:

1. continuous ownership from the first day of the twelfth month preceding the month of disposal, a minimum holding of 12 months, with later acquisitions treated as sold first;
2. classification among immobilizzazioni finanziarie (financial fixed assets) in the first balance sheet closed during the holding period;
3. tax residence or location of the investee outside the privileged regimes identified by the Art. 47-bis(1) criteria, or proof of the Art. 47-bis(2)(b) condition, including through an interpello (an advance ruling request);
4. the investee carrying on a commercial enterprise within the meaning of Art. 55.

Condition (c) must hold continuously from the first period of ownership, condition (d) from at least the beginning of the third tax period before the disposal. Real estate structures are shut out by an irrebuttable presumption: requirement (d) counts as unmet where the assets consist predominantly of real estate that is neither the object of the trade nor directly used in the activity.

Dividends received: 95% excluded, with two exceptions

Dividends received by a resident company from the companies and bodies listed in Art. 73(1)(a), (b) and (c) are excluded from income for 95%, in whatever form and under whatever name, in the period of receipt (Normattiva: TUIR, Art. 89). So 5% is effectively taxed. Two exceptions cut into that: for IAS/IFRS preparers, dividends on instruments held for trading are included in full, and profits from jurisdictions with a privileged tax regime are excluded only for 50%, and then only where the Art. 47-bis(2)(a) condition is proved, including through an interpello, with a credit under Art. 165 for the taxes paid by the investee.

Patent box: a 110% uplift on qualifying R&D

R&D costs relating to software protected by copyright, industrial patents and industrial designs and models, used by the taxpayer directly or indirectly in its business, are increased by 110% under Art. 6(3) D.L. 146/2021. The election lasts five tax periods, is irrevocable and renewable. Research must be carried out by the taxpayer itself, though contracts with companies outside the group, with universities and with research bodies are allowed. The election applies for IRAP as well, which makes the maggiorazione del 110 per cento (the 110% uplift) one of the few reliefs reaching both taxes.

Patent box for a non-resident, and the eight-year look-back

Non-residents sit inside this regime: the persons listed in Art. 73(1)(d) TUIR qualify provided they are resident in a country with which a double tax treaty is in force and with which the exchange of information is effective. Where costs are incurred with a view to creating an intangible asset, the uplift may be taken from the tax period in which the asset obtains a titolo di privativa industriale (an industrial property title), and it does not reach costs incurred before the eighth tax period preceding that one. Documentation on the Agenzia's template, flagged in the return, removes the Art. 1(2) D.Lgs. 471/1997 penalty if the uplift is later adjusted.

Does the global minimum tax apply to your Italian company?

Pillar Two turns up in generative answers to this query and alarms readers who have nothing to do with it. The global minimum tax has a size threshold, and the threshold is the whole point.

The EUR 750 million group revenue threshold

Rules apply to undertakings located in Italy belonging to a multinational or national group with annual revenue of at least EUR 750 million in the consolidated accounts of the ultimate parent, where the threshold is reached in at least two of the four preceding financial years (Art. 10(1) D.Lgs. 209/2023). Below it the regime does not engage.

The three forms of top-up tax

Three taxes implement the regime in Italy. The imposta minima integrativa is charged on Italian parent entities; the imposta minima suppletiva applies where an equivalent tax has not been charged in another country; the imposta minima nazionale falls on low-taxed entities located in Italy. Each financial year counts as a tax period in its own right.

What this means for a founder-owned S.r.l.

An ordinary S.r.l. owned by a foreign founder does not fall inside the global minimum tax regime. Group revenue of EUR 750 million describes a different order of business from the companies this page is written for, and nothing in Pillar Two changes the 24% and 3.9% above.

What foreign founders get wrong about Italian corporate tax

Treating 27.9% as an effective rate in the business plan

Budget models reach us with 27.9% applied to forecast accounting profit, and they are wrong in both directions at once. A company that will staff up on permanent contracts has overstated its tax; one built on fixed-term staff and debt has understated it. Rebuilding the model on two bases moves the funding requirement.

Assuming the filing deadline follows the balance sheet approval

Foreign directors read the Italian calendar through their home rules and tie the return to the shareholders' meeting. The return follows the closing date of the tax period and nothing else. Approval timing can move a payment date, never the filing date, and the discovery arrives late in October.

Missing the PEX classification in the first balance sheet

PEX is lost in the accounts long before any share changes hands. The holding has to be classified among immobilizzazioni finanziarie in the very first balance sheet closed during the holding period, and a later classification cannot repair it.

Asking about Art. 27-bis relief after the dividend has already been paid

The most expensive question we receive is asked a week too late. Exemption at source needs the certificate and the declaration in hand before the payment date; afterwards only the refund remains. Arranging the holding and the paperwork before the first distribution belongs to setting the company up properly, which is where our incorporation service and the tax work meet.

Frequently asked questions about corporate tax in Italy

Rates and how they combine

Who pays, and when

Taking profit out

Reliefs, thresholds and the personal layer