Corporation tax

Italian companies must pay a national corporation tax (IRESImposta sul Reddito delle Società) on profits as well as regional corporation tax (IRAPImposta Regionale sulle Attività Produttive).

National corporate tax (IRES)

The rate of national corporation tax (IRES) is currently 24%. The rate of regional corporation tax (IRAP) may vary from region to region and it is normally around 3,9%.

An Italian company must file a notice of its existence to the Inland Revenue (Agenzia delle Entrate) immediately after its incorporation and open a VAT position (Partita IVA). An Italian company must file with the Inland Revenue a Corporation Tax Return no later than 12 months after its accounting reference date.

Italian tax resident companies must pay Italian corporation tax on their worldwide income and gains, subject to double taxation relief.

Should any corporation tax be due in Italy, this must be paid 9 months after the accounting reference date. Should either of these dates be missed then penalties and interest become payable.

Regional tax on production activities (IRAP)

The regional tax on production activities (IRAP) is a local tax collected by the Region where the production activities liable for tax are conducted.

If taxpayers perform their activities in establishments and offices situated on the territory of several regions, the distribution of the taxable income, and, therefore, of IRAP is made in proportion to the cost of the employees working in the various regional establishments and offices.

Persons subject to IRAP

IRAP is due to those regularly engaged in an independently run activity in the production of goods or services in the Region.

In particular, the following persons are subject to IRAP:

  • entities subject to IRES: resident commercial companies and institutions, and non-resident companies and institutions of any type with or without legal status;
  • joint-name partnerships, limited partnerships and those equivalent to simple partnerships practicing arts and professions and professional associations;
  • agricultural producers receiving agricultural income (individuals or groups), except for those exempt from VAT;
  • public and private non-commercial institutions and public administrations;
  • individuals receiving company income; and individuals receiving income from self-employed work.

IRAP does not apply to mutual investment funds, pension funds, European economic interest groups (EEIG) and door-to-door salesmen.

For persons not resident in Italy, IRAP only applies when the activities are conducted over a period of at least three months through a permanent establishment.

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