An Italian company pays two taxes on its activity. IRES, the corporate income tax, is 24% of taxable income. IRAP, the regional production tax, is an ordinary 3.9% of the net value of production, a different base. This is the 2026 law, which ends on 31 December 2026. For a company, the income tax is IRES; the personal tax is a different tax.
The two taxes, who pays which, the filing dates and the profits sent abroad are set out below. For a company run from abroad, the same facts feed planning IRES and IRAP for a company run from abroad, which the firm prepares with the founder.
What taxes does an Italian company pay on its profit?
Two, and they are not one rate. IRES (imposta sul reddito delle società) is a State tax on the company's adjusted accounting profit. IRAP (imposta regionale sulle attività produttive) is a regional tax on a different base, the net value of production (valore della produzione netta). Both are collected by the Agenzia delle Entrate, the Italian Revenue Agency, and both are paid by form F24, the single payment form. The Agenzia delle Entrate is the body a reader may know elsewhere as the tax authority or "IRS".
Added together, the two statutory rates for an ordinary company are 24% plus 3.9%, which is 27.9%. That sum is arithmetic only. It is not a published effective rate and it is not a rate on accounting profit, because the two taxes are charged on different bases, as the Agenzia delle Entrate IRES page and the IRAP 2026 instructions show.
- Kind of tax
- State tax
- Base
- Adjusted accounting profit
- Kind of tax
- Regional tax
- Base
- Net value of production
- Loss year
- Due also in a loss year
24% + 3.9% = 27.9%: arithmetic, not a rate on accounting profit; the bases differ
What is the IRES rate in Italy, and who pays it?
The IRES rate is 24%. Art. 77(1) TUIR, the income-tax code (testo unico delle imposte sui redditi, D.P.R. 917/1986), sets the tax on total net income at 24%, and Normattiva shows that text in force to 31 December 2026. The base starts from the income-statement result, adjusted by the TUIR rules (Art. 83(1) TUIR).
A resident S.r.l., S.p.A., S.a.p.a. or cooperative pays IRES on all its income, wherever it arises. A non-resident company pays only on income produced in Italy, as the Agenzia delle Entrate states. Losses carry forward without time limit and offset up to 80% of each later year's taxable income; the losses of the first three periods of a new productive activity offset the full taxable income (Art. 84 TUIR). Net interest expense is deductible up to 30% of the gross operating result, the risultato operativo lordo or ROL, plus ROL carried forward (Art. 96(2) TUIR). The Italian terms are glossed because they are the words on the return.
Is the reduced 20% IRES rate still available?
The reduced 20% rate was enacted for one tax period only: the period after the one in progress at 31 December 2024. For a company with a calendar financial year, that is FY2025. The Agenzia delle Entrate gives the rate on this basis, under L. 207/2024 Art. 1, paragraphs 436 to 444.
The rate was conditional on reinvestment and hiring: part of the profit set to a reserve and invested in qualifying assets in Italy, and no fall in headcount. This page does not state the full list of conditions, and it states nothing about 2026: the rate is described as enacted for FY2025 only.
What is IRAP, and why is it not a tax on profit?
IRAP is charged at an ordinary 3.9% of the net value of production. The base is the difference between the value and the costs of production, without staff costs, without certain items of the income statement listed in Art. 2425 of the Civil Code (items 10(c)-(d), 12 and 13) and without extraordinary items from transfers of a business, under Art. 5(1) D.Lgs. 446/1997. Art. 2425 is named here only as the list of base items. A company always pays IRAP, because its activity is in every case the taxable event, and that includes a year in which it makes a loss (Art. 2(1) D.Lgs. 446/1997). The total cost of employees on open-ended contracts is deductible from the base (Art. 11(4-octies) D.Lgs. 446/1997).
There is a printed-rate trap. The text of Art. 16(1) D.Lgs. 446/1997 on Normattiva, in force from 21 February 2026, still shows 3.50%. The reduction was repealed in 2014 and the text was not restored, so the rate the Agenzia delle Entrate applies, in its IRAP 2026 instructions, is 3.9%.
Why does the IRAP rate differ by region and sector?
Three things move the 3.9%, and the rate on a given return depends on all three.

Regions
Each region may move the IRAP rate by up to 0.92 percentage points, by sector and category, and an ordinary-statute region may cut it to zero (IRAP 2026 instructions). The regional tables were not read, so this page gives no figure for any region or city.
Sector rates
The operative rates are 4.20% for concession holders other than motorways and tunnels, 4.65% for financial intermediaries and 5.90% for insurers. The older sector rates still printed in the statute text are a relic and are not used here.
2026 surcharges
For 2026 and 2027 the rate rises by 2 points for those mainly engaged in an activity under the ATECO codes of the table to D.L. 21/2026, so 5.9% on the ordinary rate. Banks and insurers pay 2 points more from the period after 31 December 2025, with a EUR 90,000 deduction in the two later periods.
Which companies pay a different rate?
One schedule shows who pays what in 2026. The table states conditions and does not tell the reader which row is theirs.
IRES and IRAP by type of taxpayer in 2026, with the surcharge or condition that applies.
| Taxpayer | IRES | IRAP | Surcharge or note | Source |
|---|---|---|---|---|
| Ordinary company in a region at the ordinary rate | 24% | 3.9% | None | Agenzia delle Entrate, 2026 |
| Company qualifying for the reduced rate | 20% for FY2025 only, on reinvestment and hiring conditions | 3.9% | Nothing is stated for 2026 | L. 207/2024 Art. 1 |
| Financial intermediary | 24% + 3.5 points = 27.5% | 4.65% | IRAP +2 points for banks from the period after 31 December 2025 | Art. 77 TUIR; Art. 16 D.Lgs. 446/1997 |
| Insurer | 24% | 5.90% | IRAP +2 points; EUR 90,000 deduction in the two later periods | Art. 16 D.Lgs. 446/1997 |
| Concession holder other than motorways and tunnels | 24% | 4.20% | None stated | Agenzia delle Entrate, 2026 |
| Company in an ATECO sector listed in D.L. 21/2026 | 24% | 3.9% + 2 points = 5.9%, for 2026 and 2027 | Sector list not given here | D.L. 21/2026 |
| Shell company (società di comodo) | 24% + 10.5 points | 3.9% | Not applied in the first tax period | Agenzia delle Entrate; Art. 30 L. 724/1994 |
| Company in a region that has moved the rate | 24% | Ordinary rate moved by up to 0.92 points, or to zero in an ordinary-statute region | Regional tables not given here | Agenzia delle Entrate, 2026 |
Source line: Agenzia delle Entrate (IRES page and IRAP 2026 instructions), Normattiva (Art. 77 TUIR, Art. 16 D.Lgs. 446/1997), as at 9 October 2026.
The 27.9% in the earlier section is arithmetic on the first row only. The shell-company test does not apply in the first tax period, nor to companies with at least ten employees in the two previous years (Art. 30(1) L. 724/1994).
Does a company run from abroad pay Italian corporate tax?
An Italian S.r.l. with its registered office in Italy pays IRES as a resident company, whoever runs it. Residence rests on three tests that are alternatives, each applied for most of the tax period (Art. 73(3) TUIR):
- the registered office (sede legale) is in Italy;
- the place of effective management (sede di direzione effettiva) is in Italy;
- the ordinary management is mainly in Italy (gestione ordinaria in via principale).
A foreign holding of an Italian company is presumed Italian-resident (esterovestizione, a foreign residence that is not real) where it is controlled by Italian residents or run by a board mostly of Italian-resident directors, unless it proves otherwise (Art. 73(5-bis) TUIR). The firm explains the presumption in the esterovestizione guide. This page does not say where a company should be managed.
A foreign company with no Italian subsidiary pays IRES only on income produced in Italy. It pays IRAP only through a permanent establishment (stabile organizzazione), a base or an office active in a region for at least three months, under Art. 12(2) D.Lgs. 446/1997.
Where do the residence and activity-code questions get looked at?
A company run from abroad should settle residence and the activity code before the first tax year starts.
How much tax does EUR 100,000 of profit bear?
This is the mechanics, not a personal calculation. If taxable income equals EUR 100,000 after the TUIR adjustments, IRES at 24% is EUR 24,000. IRAP is 3.9% of a different base, the net value of production, so it cannot be read off the profit. A share of the IRAP then comes off the IRES base: a flat 10% of IRAP, plus the IRAP on the taxable share of staff costs (Art. 6 D.L. 185/2008). The source the research reused marks that rule in force only to 31 December 2026. No total is given, because the second base is the company's own.
When are the returns filed and the taxes paid?
For a company with a calendar financial year, the Redditi SC return and the IRAP return are due by the last day of the tenth month after year end. For FY2025 that is 2 November 2026, because 31 October 2026 falls on a Saturday, as the Agenzia delle Entrate Redditi SC page states. The balance of IRES and IRAP and the first advance (acconto) fall due on 30 June, or 30 days later with 0.40% interest. The second advance is due on 30 November, at 60% of the prior-year amount, or 50% for taxpayers under the ISA tax-reliability indices. The Agenzia delle Entrate payments page sets these dates.
Calendar-year company, 2026
- Annual books chargeThe company, by F2416 March: EUR 309.87, code 7085
- Balance and first advanceThe company, by F2430 June, or 30 days later with 0.40% interest
- FY2025 returnsThe company or an authorised intermediary2 November 2026 (31 October is a Saturday)
- Second advanceThe company, by F2430 November: 60% of prior year, 50% for ISA taxpayers
2026 deferral for ISA taxpayers
- Deferred balance and first advanceThe company, by F2420 July 2026, or 30 days later at 0.80%
The company or an authorised intermediary files and pays: the transmission of the return is open only to the intermediaries listed in Art. 3(3) D.P.R. 322/1998, and the firm prepares the return and coordinates, but does not transmit it. Filing and paying online need SPID, CIE, CNS or Entratel credentials, which a foreign director usually lacks. The calendar and the return are set out in corporate tax filing in Italy.
The tax calendar of a calendar-year company in 2026, with who acts at each date.
| Event | Date | Who acts | Source |
|---|---|---|---|
| Redditi SC and IRAP returns | Last day of the tenth month; 2 November 2026 for FY2025 | The company or an authorised intermediary | Agenzia delle Entrate, Redditi SC 2026 |
| Balance and first advance | 30 June, or 30 days later with 0.40% interest | The company, by F24 | Agenzia delle Entrate, payments |
| Second advance | 30 November; 60% of the prior-year amount, 50% for ISA taxpayers | The company, by F24 | Agenzia delle Entrate, payments |
| IRAP advance | 100% of the prior year's IRAP above EUR 20.66, with 40% and 60% on the IRES dates | The company, by F24 | IRAP 2026 instructions |
| 2026 deferral for ISA taxpayers | 20 July 2026, or 30 days later at 0.80% | The company, by F24 | Agenzia delle Entrate, payments |
| Annual books charge | 16 March, EUR 309.87 at standard capital, F24 code 7085 | The company, by F24 | Agenzia delle Entrate, F24 charge |
Source line: Agenzia delle Entrate, as at 9 October 2026. The annual charge on the corporate books is a separate yearly cost and not a tax on profit.

What is withheld when profits go to a foreign parent?
The Italian S.r.l. is the withholding agent: it keeps the tax when it pays the dividend. Under Art. 27 D.P.R. 600/1973 the default is 26% final on a dividend to a non-resident shareholder, and 1.20% for an EU/EEA company, from 1 January 2026. The printed 27% and 20% in the statute text are relics and are not used here. Under Art. 27-bis D.P.R. 600/1973 there is no withholding for an EU parent that holds at least 10% without interruption for at least one year, with the foreign tax authority's certificate in hand by the payment date.
These texts end on 31 December 2026 on Normattiva. The sources read do not say whether the certificate needs an apostille or a sworn translation, so this page says nothing on that point. The S.r.l. dividends tax in Italy guide works through the rate, and our guide to the tax residence certificate covers the related residence certificate. For a US shareholder, what the treaty protects a US shareholder from is set out separately.
What leaves Italy with the profits in 2026, and what an Italian company receives.
| Flow | Withholding or treatment | Condition | Source |
|---|---|---|---|
| Dividend to a non-resident shareholder | 26% final | Default rate | Art. 27(3) D.P.R. 600/1973 |
| Dividend to an EU/EEA company | 1.20% final | Holdings not connected with an Italian permanent establishment; from 1 January 2026 | Art. 27(3-ter) D.P.R. 600/1973 |
| Dividend to an EU parent | No withholding | At least 10% held without interruption for at least one year; the foreign tax authority's certificate by the payment date | Art. 27-bis D.P.R. 600/1973 |
| Royalties paid abroad | 30% final on the taxable part | EU associated companies exempt on the conditions of Art. 26-quater | Art. 25(4) D.P.R. 600/1973 |
| Dividends received by an Italian company; gains on qualifying holdings (PEX) | 95% excluded from IRES; gains 95% exempt | Gains after 12 months and the other Art. 87 conditions | Arts. 89 and 87 TUIR |
Source line: Normattiva, as at 9 October 2026; the D.P.R. 600/1973 texts end on 31 December 2026.
What does a founder abroad fix before the first tax year?
The sequence below assumes a company with a calendar financial year. The notary files the deed; the company or an authorised intermediary transmits the return; the firm prepares and coordinates and never transmits.
Fix the main activity and its ATECO code
Do this before the deed. The code decides whether the 2026 and 2027 IRAP surcharge applies. The surcharge is statute; fixing the code before the deed is the firm's practice.
Decide where the company is managed
The residence tests apply for most of each tax period. Every director and shareholder needs a codice fiscale, set out in our guide to the codice fiscale. The choice of place is the founder's.
Trade and keep the books in year one
The advances are measured on the prior year's tax. Invoices and records follow electronic invoicing in Italy.
Pay the balance and the first advance on F24
The date is 30 June, or 30 days later at 0.40% interest. A director abroad needs an Italian payment channel or an authorised intermediary.
File the returns online
The date is the last day of the tenth month; 2 November 2026 for FY2025. The company or an authorised intermediary acts.
Pay the second advance
The date is 30 November, at 60% of the prior-year amount, or 50% for ISA taxpayers.
Pay the dividend to the foreign parent
The S.r.l. withholds 26%, or 1.20% for an EU/EEA company, or nothing under the Parent-Subsidiary rule. The foreign tax authority's certificate must be in hand by the payment date.
What changes on 1 January 2027?
A new income-tax code replaces the TUIR. D.Lgs. 19 June 2026 n. 117, published in the Gazzetta Ufficiale n. 152 of 3 July 2026 (supplement no. 26), has been in force since 4 July 2026, and its Title II, Arts. 81 to 159, is the IRES. Normattiva shows Art. 77 TUIR, the article that sets the 24%, as repealed from 1 January 2027. Arts. 24-ter, 73, 87, 89 and 162 TUIR are likewise marked in force only to 31 December 2026, while Art. 16 D.Lgs. 446/1997 on IRAP carries no end date.
This page states the 2026 law with its end date. It does not say that the 24% continues, because the code's application date and rate article were not read, and it prints no article number of the new code.
From our practice
Federica Conti works on the tax side of foreign-owned Italian companies in Rome, in Italian, English and French. We ask the founder to fix the main activity and its ATECO code before the deed, so that the surcharge question is answered at filing, not afterwards.
Is the company rate the same as the Italian income tax rate?
No. For a company, the income tax is IRES, at the rate above. The personal income tax is a different tax, and this page gives none of its rates. A search for the Italy tax rate, Italy tax rates or the income tax rate in Italy often means the personal tax. The Italy income tax rate for a person, and the Italy income tax rates by bracket, belong to that tax, and this page gives none of them.
Two other names cause confusion. The "7% rule" is an individual's regime: a pensioner who moves to a qualifying small southern municipality pays a 7% substitute tax on foreign income (Art. 24-ter TUIR). It is not a company rate. Pillar Two, the global minimum tax, applies to groups with consolidated revenue of EUR 750 million or more in at least two of the four previous years (Art. 10(1) D.Lgs. 209/2023); an ordinary S.r.l. of a founder is outside it. A company's crypto gains are a separate question, covered in how crypto gains are taxed in Italy.
Sources
The official texts this guide rests on, each with what it supports.
- Agenzia delle Entrate, IRES: the 24% rate, who pays, residence tests, the FY2025 20% rate.
- Agenzia delle Entrate, IRAP 2026 instructions: the 3.9% rate, sector rates, regional power, the base.
- Normattiva, Art. 77 TUIR: the 24% in the statute and its end date.
- Normattiva, Art. 16 D.Lgs. 446/1997: the printed 3.50% and the 2026 surcharges.
- Normattiva, Art. 27 D.P.R. 600/1973: dividend withholding, including the 1.20% rate.
- Normattiva, Art. 27-bis D.P.R. 600/1973: Parent-Subsidiary relief.
- Agenzia delle Entrate, income-tax payments: payment dates, advances, interest.
- Agenzia delle Entrate, Redditi SC 2026: the return date.
- Normattiva, D.Lgs. 117/2026: the new income-tax code.
Related service
- planning IRES and IRAP for a company run from abroad: the tax advice behind the rates on this page, prepared with the founder.
- corporate tax filing in Italy: the calendar and the return, prepared by the firm and transmitted by the company or an authorised intermediary.
Questions on a particular company go through our contact page.
