OECD published the updated list of countries, including Italy (with 15 %), that have obtained the transitional status of qualified legislation concerning the Income Inclusion Rule, the Undertaxed Profit or Payment Rule, or the Qualified Domestic Minimum Top-up Tax, following the review process conducted by the OECD Inclusive Framework on BEPS Pillar II. On october [...]

The provision of the TUIR, which requires a proportional reduction of the deductible foreign tax when foreign income only partially contributes to the taxable base, could be overridden by the rules preventing double taxation contained in many of the treaties signed by Italy, as these do not include such a provision.

In line with EU case law, the interference of a holding company in the management of the companies in which it holds shares constitutes an economic activity, thereby granting the right to VAT deduction. However, this applies only if such interference involves transactions subject to VAT (national ruling).

According to the new paragraph 15-quater of Article 173 of the Consolidated Income Tax Act, the spin-off of a company and the subsequent transfer of the acquired participation are not relevant for income tax purposes. In this regard, it is officially clarified that the spin-off of a business unit followed by the transfer of the [...]

The Italian Revenue Agency (Agenzia delle Entrate), by means of its reply No. 8 of 21 January 2025, has ruled on the issue of dividend washing: According to the Agenzia delle Entrate, the provision on dividend washing is not applicable whenever the shareholdings do not meet the objective PEX requirements, i.e. they are related to [...]

The limited liability company in Italy is a kind of company that allows small social enterprises to benefit from limited liability. The srl, like the spa, acquires the legal personality with the registration in the Company Register held at the Chmaber of Commerce.The srl can be set up with an agreement between the quota holders [...]

The rate of corporate income tax (IRES) is 24%. Who is liable to pay IRES The following must pay the tax: public limited companies and limited companies limited by shares, limited liability companies, cooperative societies and mutual insurance companies, European companies (Regulation (EC) No 2157/2001) and European cooperative societies (Regulation (EC) No 1435/2003) resident in Italy; public [...]

The Revenue Agency is the authority responsible for the electronic invoicing procedure. All invoices that economic operators resident or established in Italy issue to other economic operators must be in electronic form . Non-Italian economic operators can issue invoices in paper or electronic form. All electronic invoices must be sent to the Exchange System (SdI [...]

Italian corporate entities and non-resident companies, only on Italian source income, are subject to a corporate income tax , Ires, and to a regional production tax, Irap. The regional production tax (Irap) is a local tax on productive activities realized within a regional territory. The standard rate is 3.9%, but higher Irap rates are, for [...]

The standard VAT rate in Italy is 22%. Reduced rates are applied to specific goods and services: 4%, for example, for some foodstuffs, beverages and agricultural products; 5%, for example, for some foodstuffs; 10%, for example, for the supply of electricity and gas for household use, medicines, building renovation works and specified goods and services.