Italy Corporate Tax 2026: 24% IRES, 3.9% IRAP, VAT & Business Guide
What taxes does your company pay in Italy in 2026? Flat 24% IRES corporate rate, 3.9% IRAP regional tax, 22% VAT, withholding taxes, and filing rules for SRL, SPA, branches, and sole proprietors.
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Tax Residency and Rates
A company is an Italian tax resident if its registered seat, effective management, or principal place of business is in Italy for the majority of the tax period. Residents pay IRES on worldwide income. Non-residents pay IRES only on Italian-source income. All companies also pay IRAP on the value generated by productive activities within each region where they operate.
Italian residents: 24% IRES on worldwide income
Non-residents: 24% IRES on Italian-source income only
IRAP standard rate: 3.9% (can vary ±0.92% by region)
Banks and financial institutions: IRAP 4.65% (raised to 6.65% for 2026–2028)
Shell/dormant companies: IRES surcharge of 10.5% applies
Key 2026 Budget Law Changes
The 2026 Budget Law (published in the Italian Official Gazette on 31 December 2025) introduced several corporate tax changes effective from 1 January 2026.
Dividend exemption (95% IRES exclusion) now requires a minimum 10% direct or indirect participation threshold
Tobin Tax rates doubled: 0.4% on OTC equity transfers, 0.2% on regulated market trades
New hyper-depreciation incentive replaces Transition 4.0/5.0 tax credits for investments from Jan 2026 to Sep 2028
Cooperative compliance regime threshold lowered from €750M to €500M turnover
IRAP increased by +2 percentage points for banks and financial intermediaries for 3 years
SRL (Società a Responsabilità Limitata)
IRES Corporate Tax Rate
24%
Flat rate on net taxable profits
IRAP Regional Tax
3.9%
Standard rate (varies by region)
Minimum Share Capital
€1–€10,000
€1 allowed, €10,000 standard
Most popular structure for SMEs and foreign investors
Limited liability for shareholders (quotisti)
Separate legal entity; worldwide income taxed
Dividends to individuals: 26% WHT
No residency requirement for shareholders or directors
SPA (Società per Azioni)
IRES Corporate Tax Rate
24%
Flat rate on net taxable profits
IRAP Regional Tax
3.9%
Standard rate (varies by region)
Minimum Share Capital
€50,000
25% paid in before incorporation
Preferred for large companies and public listings
Shares freely transferable; limited liability
Same IRES/IRAP rates as SRL
More complex governance requirements
Required for companies listing on Italian stock exchange
Impresa Individuale (Sole Proprietor)
Tax Rate
23–43%
Progressive IRPEF personal income tax
IRAP
Exempt
Individuals abolished from IRAP since 2022
Liability
Unlimited
Personal assets fully at risk
Taxed under IRPEF (personal income tax), not IRES
No separate legal entity; unlimited personal liability
Exempt from IRAP since 2022 Budget Law
Flat-rate forfettario regime available if turnover ≤ €85,000
Suitable for freelancers and small sole-trader businesses
Branch of Foreign Company (Stabile Organizzazione)
IRES on Italian profits
24%
Italian-source income only
IRAP
3.9%
On Italian value added
Branch Remittance Tax
None
No withholding on repatriated profits
Taxed only on Italian-source income attributed to the branch
Parent company retains full legal liability
No withholding tax on profit repatriation to parent
Must register with Registro delle Imprese and obtain Partita IVA
Transfer pricing rules apply between branch and head office
VAT (IVA) in Italy 2026
VAT Rates
Italy's VAT (called IVA - Imposta sul Valore Aggiunto) applies to most business transactions. There is no domestic registration threshold - any taxable business activity requires a Partita IVA. Electronic invoicing via the SdI platform is mandatory for all VAT-registered entities.
Standard rate: 22% - applies to most goods and services
Reduced rate: 10% - food products, tourism, hotel accommodation
Reduced rate: 5% - social housing, specific food items
Super-reduced rate: 4% - basic foodstuffs, books, newspapers, certain medical supplies
No VAT registration threshold for non-residents; EU threshold of €10,000 applies for B2C cross-border sales under OSS
VAT Filing Deadlines
All VAT-registered businesses must submit periodic VAT settlement returns (Comunicazione Liquidazioni Periodiche IVA) and an annual VAT return.
Monthly VAT: due by the 16th of the following month (mandatory if annual turnover > €400K for services or > €700K for goods)
Quarterly VAT: due by the 16th of the second month following the quarter
Annual VAT return (Modello IVA Annuale): filed between 1 February and 30 April of the following year
Electronic invoicing (fattura elettronica) via SdI: mandatory for all SRL, SPA, and other entities with a Partita IVA
Withholding Taxes and Dividend Taxation
Dividend Withholding Tax
Italy applies different withholding tax rates depending on who receives the dividend. The 2026 Budget Law tightened access to preferential rates by adding a minimum participation threshold.
Individuals (resident and non-resident): 26% WHT on dividends
Italian corporate shareholders: 95% exemption from IRES taxable income (requires ≥10% participation from 1 Jan 2026)
EU/EEA corporate recipients: 1.2% WHT (requires ≥5% share capital or ≥€500,000 tax value participation)
EU parent companies qualifying under Parent-Subsidiary Directive: 0% WHT (minimum 10% holding for ≥1 year)
Non-EU non-residents: 26% WHT, reduced by applicable double tax treaty
Other Withholding Taxes
Italy withholds tax on a range of outbound payments. Treaty rates may reduce or eliminate withholding on interest and royalties.
Interest payments to non-residents: 26% WHT (standard domestic rate)
Royalties to non-residents: 30% WHT on 75% of gross amount (effectively 22.5%); reduced by treaty
EU Interest & Royalties Directive: 0% WHT on qualifying intra-group interest and royalties
Capital gains - Participation Exemption (PEX): 95% of gains on qualifying share sales exempt from IRES
Tax Deductions, Losses, and Incentives
Loss Carry-Forward
Italy allows indefinite carry-forward of tax losses, but the annual offset is capped. There is no carry-back.
Losses carried forward: indefinitely, with no time limit
Annual utilization cap: losses can only offset up to 80% of taxable income each year (companies must always pay IRES on at least 20% of taxable profit)
Exception: losses from the first 3 years of activity can be used without the 80% cap
Key 2026 Investment Incentives
The 2026 Budget Law introduced a new hyper-depreciation regime for capital investments, replacing the previous Transition 4.0 and 5.0 tax credit systems.
New hyper-depreciation: acquisition cost of capital goods increased for depreciation purposes at progressive rates depending on investment size
Applies to investments from 1 January 2026 through 30 September 2028 in assets produced in EU/EEA countries
Design and aesthetic ideation tax credit: 10% of eligible costs, up to €2 million annually; extended to 2026
R&D tax credit: available for qualifying research and development expenditure
Global Minimum Tax (QDMTT): large groups with revenues over €750M must ensure a 15% effective tax rate
Employer Taxes and Social Contributions
INPS and INAIL Contributions
Employers in Italy pay mandatory social security contributions to INPS (national pension and welfare) and INAIL (workplace accident insurance). The rates are among the highest in Europe.
Employer INPS contributions: typically 27–32% of gross salary (varies by sector, collective agreement, and company size)
Employee INPS contributions: approximately 9–10% of gross salary
INAIL (accident insurance): additional percentage depending on risk classification of the activity
Regional surcharges (addizionale regionale): 1.2–3.33% of gross income withheld by employer
Municipal surcharges (addizionale comunale): 0.1–0.9%, also withheld by employer
Corporate Tax Filing and Deadlines
Key Deadlines for Calendar-Year Companies
Italy's corporate tax year generally follows the calendar year. All IRES and IRAP returns must be filed electronically via the Agenzia delle Entrate portal using form Redditi SC.
IRES/IRAP return filing deadline: 31 October of the year following the tax year (e.g., 31 October 2026 for FY 2025)
IRES/IRAP balance payment (saldo): end of the 6th month following year-end (30 June for calendar-year entities)
First advance payment (acconto): 30 June (40% of prior year tax for most taxpayers)
Second advance payment (acconto): 30 November (60% of prior year tax)
Annual VAT return: filed 1 February – 30 April of the following year
Payment via form F24 through the Agenzia delle Entrate portal (Fisconline/Entratel)
Calculate Your Italian Corporate Tax
Estimate IRES and IRAP liability, VAT obligations, withholding tax on dividends, and employer social contributions. Compare SRL vs SPA vs branch taxation for your business in Italy.