This guide follows both directions, with the law as in force in 2026. For the tax work around a company in Italy, see tax advice for a company in Italy.
What is the Italian tax residence certificate, and what is it for?
The tax residency certificate in Italy is a document the taxpayer asks the Agenzia delle Entrate for, to claim the benefits of the international double tax conventions and of EU law. The Agenzia describes it in those words. It also calls the document certificato di residenza fiscale, and this page uses "certificate" and "attestation" for the same thing (Agenzia delle Entrate).
Income of several types produced in the same foreign State gets one single certificate. A company with dividends and royalties from one country therefore asks once for that country.
The Agenzia's legal-basis page cites no statute article for the attestation itself. It lists three entries: the decision of the Director of the Agenzia of 10 July 2013, Directive 2003/49/EC on interest and royalties, and Directive 2011/96/EU on parents and subsidiaries.
Which way does the certificate run, and which one do you need?
There are two directions, and they are different documents. In the outbound direction, Italy certifies an Italian resident to a foreign State: the Agenzia issues the attestato. In the reverse direction, the recipient's own tax authority certifies a non-resident to the Italian payer (Agenzia delle Entrate, treaty models).
A one-line test: ask who receives the income, and in which State the relief is claimed. If an Italian company receives income from abroad, the outbound direction applies. If a founder or parent abroad receives dividends, interest or royalties from an Italian company, the reverse applies, and the section on what a founder or parent abroad needs covers it.
Who can ask the Agenzia delle Entrate for it?
Four groups of residents may ask, according to the Agenzia (Agenzia delle Entrate).
- Resident individuals. A person resident in Italy for tax purposes may ask for a certificate addressed to the foreign State where the income arose.
- Capital companies. The società di capitali, which includes the S.r.l. and the S.p.A., may ask in the company's own name through its legal representative.
- Commercial and non-commercial entities. Entities with or without a trading activity may ask, if they are resident in Italy.
- Collective investment bodies and pension funds. Both are listed by the Agenzia among the resident entities that may ask.
A partnership or other fiscally transparent entity cannot ask in its own name. Only its resident partners or beneficiaries can.
What are the requirements to be considered a tax resident in Italy?
An individual is resident if, for most of the tax period, the person has civil-law residence, domicile or presence in Italy. Registration in the anagrafe presumes residence, and the Agenzia reads the threshold as 183 days, 184 in a leap year (Art. 2(2) TUIR, in force to 31 December 2026). For a company, see the next section.
Does an Italian S.r.l. owned from abroad qualify?
A company is resident in Italy if, for most of the tax period, it has in Italy its sede legale (registered office), its sede di direzione effettiva (place of effective management) or its gestione ordinaria in via principale (main ordinary management). Any one of the three is enough (Art. 73(3) TUIR, in force to 31 December 2026). Where a company has its sede legale in Italy for most of the tax period, the first test is met whoever owns it.
Effective management is the continuous and coordinated taking of the strategic decisions concerning the company as a whole. The certificate records a residence that the law already attributes. It does not create one.
Residence cannot be settled in advance by interpello (advance ruling), because it is a question of fact (Circolare 20/E of 4 November 2024). The company is therefore resident or not by the facts of the year, and the certificate follows from them.
What if a founder moves to Italy and keeps a foreign holding?
Two rules decide who ends up asking Italy for this certificate. The first is the individual test in Art. 2(2) TUIR, as replaced by D.Lgs. 209/2023 from 1 January 2024: civil-law residence, domicile or presence in Italy for most of the tax period, with registration in the anagrafe presuming residence (Art. 2 TUIR).
The second is Art. 73(5-bis) TUIR. A foreign company that controls an Italian company is presumed Italian-resident, unless it proves otherwise, when it is controlled by Italian residents or run by a board with a majority of Italian-resident directors (Art. 73 TUIR). Practice calls a foreign company deemed Italian-resident esterovestizione.
Both articles are in force to 31 December 2026. They state a presumption and a test. Whether either applies to a given holding is a question of fact for a tax adviser.
How is the request filed, and can a director abroad do it remotely?
Yes, in part. Two of the four filing channels need no presence in Italy: upload in the Agenzia's authenticated area and certified email (PEC). Counter and registered mail are the other two (Agenzia delle Entrate). The steps below follow the outbound request.
Confirm Italian residence for the year
The directors, with their adviser, check the company against Art. 73(3) TUIR. No advance ruling is available, so this comes first.
Find out what the foreign State wants
The company or its adviser checks the foreign administration's site for its own form, agreed with Italy or not, or for acceptance of the Agenzia's model. No term applies; it depends on the foreign State.
Complete the request
Name the foreign State, the income types, the language and the number of copies. Every field is compulsory. The legal representative signs, or a delegate holding a formal delegation.
Pay the state charge
The company or its delegate pays the charge per copy, by form F23 or a revenue stamp. The next section gives the amount.
File it
Upload in the authenticated area or PEC to any Provincial Directorate, or counter or registered mail to any territorial office. Large taxpayers file only with their Regional Directorate.
The office issues the certificate
If asked, it also signs and stamps the foreign form. No term for issue is published on the pages read.
Send it on
Give the certificate or stamped form to the foreign payer, for the treaty rate at source, or to the foreign tax administration, for a refund with proof of the tax withheld.
The outbound request at a glance, from the Agenzia delle Entrate's pages and request form.
| Item | What the Agenzia states |
|---|---|
| Who may apply | Resident individuals and resident entities; a partnership only through its resident partners or beneficiaries |
| Channels | Upload in the authenticated area, PEC, hand delivery with a receipt, registered mail with return receipt |
| Receiving office | Any territorial office or Provincial Directorate; large taxpayers only their Regional Directorate |
| Languages | Italian-English or Italian-French |
| State charge | EUR 3.10 per copy, as printed on the form read on 12 September 2026 |
| Issue time | No term published |
Source: Agenzia delle Entrate, how to obtain the attestation, and the request form (read 12 September 2026).
Every Italian company already holds a PEC by law (Art. 16 D.L. 185/2008), so the channel exists from incorporation. A company's codice fiscale and VAT number are, with exceptions, the same number; see how the Italian VAT number works and the detailed codice fiscale page. The pages read do not say whether a foreign qualified electronic signature is accepted on PEC, and they name no credential for the authenticated area.
- Authenticated area
- Remote
- Certified email
- Remote
- Hand delivery with a receipt
- In Italy
- With return receipt
- By post
Large taxpayers file only with their Regional Directorate.
No published timeWhat does the form ask for, and what does the state charge?
- The foreign State where the income arose.
- The tax year of the income.
- The capacity in which the signer acts.
- The income categories, 17 boxes in all.
- The language version: Italian-English or Italian-French.
- The number of copies requested.
- A digital signature, or a handwritten one with a copy of the signer's identity document.
- Delegation papers and the delegate's identity document where a delegate acts.
The state charge is EUR 3.10 per copy as tributi speciali, paid by form F23 with codice tributo 964T at a bank or post office, or by a revenue stamp (marca da bollo) of the same amount, as printed on the form read on 12 September 2026. The form has since moved to a new address and the current file was not opened, so check amount and code on the form you use (Agenzia delle Entrate). No page read asks for an apostille or sworn translation on the Italian request. That is our inference from how the channels are described, not a rule.
Need the residence evidence lined up?
Tell us whether the company or the founder is abroad, and we will set out the residence evidence the tax adviser needs.
What if the foreign tax office wants its own form?
The Italian resident has to act itself: the Agenzia says residents "devono attivarsi", and gives the foreign payer or tax administration the foreign form or an ad hoc request (Agenzia delle Entrate). The foreign form usually carries an Italian residence box that the taxpayer must have signed and stamped by an Agenzia Provincial Directorate.
The Agenzia's own model, approved by the decision of 10 July 2013, is used when the foreign State has prepared none. Some foreign administrations do not accept it and require their own form, stamped and signed by the competent office.
Where the foreign form is substantially similar to the Italian one, the office may attest on it and still issue its own certificate. It may also add statements, such as that the holder is liable to tax, which the Agenzia reads in treaty Art. 4 as unlimited tax liability (Agenzia delle Entrate, treaty FAQ). A refund request abroad must be accompanied by proof of the tax actually withheld.
How long does it take?
No term for the Agenzia to issue the attestation appears on the pages read, so this guide gives none. The request can be sent the same day it is completed, through upload or PEC; that is practice, not law. The issue time is set by the office, and the foreign State sets its own time for the relief it grants (Agenzia delle Entrate).
What does a founder or parent abroad need to cut Italian withholding?
A non-resident claiming a treaty rate, an exemption or a refund on Italian income uses the Agenzia's unilateral models of 10 July 2013. Agreed forms remain valid with Germany, Portugal, the United Kingdom, the United States, Sweden and Switzerland, and pensioners use model EP/I on the INPS site (Agenzia delle Entrate, treaty models).
The residence attestation comes from the tax authority of the recipient's own country, on the box of the Italian model or on that authority's form. It must attest treaty residence for the tax period or at the date of issue, and an electronic one must be verifiable (Agenzia delle Entrate, treaty FAQ).
The four reverse routes against their conditions; the table states them and does not recommend one.
| Route | What the Italian payer applies | Document the recipient supplies | Timing |
|---|---|---|---|
| Treaty rate at source | The treaty rate instead of the domestic one | Residence attestation from the home authority, on the Italian model or its own form | See the treaty and the Agenzia form |
| Parent-Subsidiary exemption | No withholding on the dividend | Certification of the competent foreign tax authority and the parent's declaration on the one-year holding | Held by the payer by the payment date |
| Interest and Royalties exemption | No withholding on the payment | Residence attestation from the recipient's authority and the recipient's declaration | In the payer's hands by the payment date; kept until the assessment terms expire |
| Refund without a treaty | Withholding applied, then refunded | Certificate of the foreign tax office proving final foreign tax on the same dividend | Claimed after the payment; up to eleven twenty-sixths of the Italian withholding |
Source: Art. 27-bis, Art. 26-quater and Art. 27 D.P.R. 600/1973, in force to 31 December 2026; Agenzia delle Entrate treaty models and FAQ. For the holding thresholds, see the statute.
The reverse route in four steps (Art. 27-bis D.P.R. 600/1973; Art. 26-quater D.P.R. 600/1973):
- Identify the route in use, with its conditions, before the dividend is resolved.
- Obtain the residence certificate from the home tax authority.
- Deliver it, with the declarations and the Agenzia form, to the Italian company by the payment date for the two EU exemptions.
- The company applies the rate or exemption and keeps the papers until the assessment terms expire.
This page does not state the holding thresholds of the two EU exemptions, nor whether a foreign certificate needs an apostille or translation. Neither is settled by the pages read.
What is withheld if the paperwork is missing?
Dividends paid to a non-resident bear a final withholding of 26 per cent (Art. 3(1) D.L. 66/2014). A non-resident shareholder who paid final foreign tax on the same dividend may recover up to eleven twenty-sixths of the Italian withholding, proved by a certificate of the foreign tax office (Art. 27(3) D.P.R. 600/1973).
For dividends to EU and EEA pension funds and to PEPP products, the rate is 20 per cent on profits paid from 12 August 2026 (D.Lgs. 148/2026); an older, lower figure is outdated. No penalty figure for a late or missing certificate is given here, because none is in the sources read.
What changes on 1 January 2027?
Arts. 2 and 73 TUIR and Arts. 26-quater, 27 and 27-bis D.P.R. 600/1973 are marked in force to 31 December 2026 and move to new codes on 1 January 2027. The successor articles were not read, so this page prints no 2027 article number. The Agenzia updated its page on the attestation on 21 September 2026 and moved the request form to a new address (Agenzia delle Entrate).
- Treat every article number here as the 2026 law.
- Check the form and the state charge on the current request form.
- Re-read this guide on or before 1 January 2027.
From our practice
The first thing we ask is which direction the client needs. A founder abroad may ask for the Italian certificate when the Italian payer is in fact waiting for one from the founder's own authority. We line up the home-country certificate and the declarations before the dividend is resolved, because the two EU exemptions look to the payment date. We do not file the request for you. Federica Conti
Sources
- Agenzia delle Entrate: what the attestation is: purpose, one certificate for several incomes.
- Agenzia delle Entrate: how to obtain the attestation: applicants, channels, large taxpayers.
- Agenzia delle Entrate: treaties, residents of Italy: foreign form stamped in Italy, refunds.
- Agenzia delle Entrate: treaty models and instructions: unilateral models, agreed forms.
- Agenzia delle Entrate: treaty FAQ: certification on a foreign form, non-resident certificate.
- Agenzia delle Entrate: Circolare 20/E of 4 November 2024: residence and interpello.
- Normattiva: Art. 73 TUIR: corporate residence, presumption.
- Normattiva: Art. 2 TUIR: individual residence.
- Normattiva: Art. 27-bis D.P.R. 600/1973: Parent-Subsidiary certificate by the payment date.
- Normattiva: Art. 26-quater D.P.R. 600/1973: Interest and Royalties attestation.
- Normattiva: Art. 27 D.P.R. 600/1973: refund, pension funds.
- Normattiva: Art. 3 D.L. 66/2014: 26 per cent withholding.
Related service
- Tax Advisory for Companies in Italy: the tax and compliance work around a company in Italy. Questions on your own file go through our contact page.
- Capital Gains Tax in Italy: the tax a seller of Italian shares or assets may face.
- Conservazione a Norma and Digital Archiving Rules: how an Italian company keeps its digital records.