Tax, VAT, bookkeeping and payroll
Tax Advisory in Italy for Companies Owned from Abroad
Tax advice for an Italian S.r.l. owned or run from abroad: what it pays, what reaches the parent, and when.
- IRES 24% · IRAP 3.9% ordinary rate, 2026
- Dividends to a foreign parent: 26% by default, none at source under Art. 27-bis
- FY2025 returns due by 2 November 2026
- In English, by video call, for owners abroad
Tax advice for an Italian company run from abroad
We advise Italian companies whose owners are abroad: a founder with a new S.r.l., a foreign parent with an Italian subsidiary, a group adviser mapping the Italian side. The work covers the company's own taxes and what it pays the group, from Rome, in English. The company comes first: see our company formation overview.
Who signs and who transmits is set by law. Returns go online to the Agenzia delle Entrate, sent by the company itself or by an enrolled intermediary on the closed list of Art. 3(3) D.P.R. 322/1998. We claim no protected title. Books and returns are prepared through our corporate tax filing service.
What's included
Advice, preparation and coordination, never a reserved act.
Structure review before the deed
The decisions the deed fixes, each with its statutory conditions: year end, board and where it meets, the parent's residence, the ATECO code.
IRES and IRAP planning input
IRES at 24% on profit, IRAP at 3.9% on the net value of production (Agenzia delle Entrate), with sector and regional variations.
Permanent-establishment check
Whether the group's own staff, agent or site in Italy creates a permanent establishment beside the subsidiary (Art. 162 TUIR).
Treaty and directive paperwork
The parent's residence certificate, the Parent-Subsidiary request and the treaty forms, ready before the first dividend or royalty leaves Italy.
Guide: Transfer Pricing in Italy
Residence review
Where the board meets and who manages the company bear on residence (Art. 73(3) TUIR); a foreign holding above the S.r.l. is reviewed under Art. 73(5-bis).
Shell-company test at year end
From the second tax period, the Art. 30 L. 724/1994 revenue test, run on year-end figures with the bookkeeper.
One first-year calendar
Payment and return dates in one calendar, shared with the bookkeeper and the intermediary who transmits.
Guides: E-Invoicing in Italy through the SDI · Esterometro and Cross-Border Invoices · INPS Registration for Employers
VAT registration sits outside this service: see a partita IVA for a non-resident and our guide to the Italian VAT number. Customs and record-keeping: customs registration for an Italian company and the digital archiving guide.
Payroll is a reserved activity (L. 12/1979 Art. 1). When you are hiring a first employee through an Italian S.r.l., an enrolled consulente del lavoro runs it and we coordinate.
Who this service is for
- A founder abroad forming an S.r.l. now
The deed fixes the year end and the first board, which set later deadlines and tax residence. We review both before signing.
- A foreign group with an Italian subsidiary or holding
Dividends or royalties paid abroad carry withholding unless the right paper is in hand by the payment date.
Service: Holding Company Set-Up in Italy
- A buyer of an existing S.r.l.
The tax position and calendar come with the company; we read both from the transfer. Companies on offer: the detailed ready-made companies page.
- A founder who moves to Italy with the company
The company's taxes are here. The founder's permit runs through the investor visa for Italy; staff hired from abroad may need an employment visa for Italy.
How the first year runs
Structure review before the deed
You, your adviser and us: year end, board, parent's residence and ATECO code, each with its conditions. No statutory term; our estimate is a few working days.
Deed and registration
The notary and the Register. The single filing gives the codice fiscale and partita IVA; we supply the ATECO code and VAT start data. See getting an Italian tax code from abroad.
Permanent-establishment check
Us, with you. A fixed place, a site over three months or an agent who habitually concludes contracts creates a PE (Art. 162 TUIR), which declares for VAT within 30 days (Art. 35 D.P.R. 633/1972). See the permanent establishment risk guide.
Treaty and directive paperwork
The parent's own tax authority issues the residence certificate; the Italian payer holds it by the payment date (Art. 27-bis D.P.R. 600/1973). Our estimate: weeks. See our guide to the tax residence certificate.
Shell-company test at year end
Us, with the bookkeeper. Not in the first tax period; from the second, revenue is tested on a three-year average (Art. 30 L. 724/1994).
First payments
The company, on F24: balance and first advance by 30 June, second advance by 30 November for a calendar year (Chamber of Commerce of the Marche, 2026 dates).
First returns
The company or its intermediary, online: Redditi SC and IRAP by the last day of the tenth month after year end; for FY2025, 2 November 2026 (Art. 2 D.P.R. 322/1998).
- Structure review before the deedYou, your adviser and usNo statutory term
- Deed and registrationThe notary and the Register; the single filing gives the codice fiscale and partita IVA
- Permanent-establishment checkUs, with youVAT declaration within 30 days of setting up a PE (Art. 35 D.P.R. 633/1972)
- Residence certificate in handThe parent's tax authority issues it; the Italian payer holds itBy the payment date (Art. 27-bis D.P.R. 600/1973)
- 30 June: balance and first advanceThe company, on F24Calendar-year company, 2026 dates
- 30 November: second advanceThe company, on F24Calendar-year company, 2026 dates
- First returns: Redditi SC and IRAPThe company or its intermediary, onlineLast day of the tenth month after year end; FY2025: 2 November 2026 (Art. 2 D.P.R. 322/1998)
Deciding the year end and the board before the deed?
The deed fixes both. Review them with us while they can still change.
Documents you will need
- The group structure chart, with each holding's percentage
- For a corporate parent, its certificate of incorporation
- For treaty or directive relief, a residence certificate from the parent's tax authority
- The board's composition and where each director is resident
- The identity documents and codice fiscale already gathered for the deed
- The intended ATECO code and a short description of the activity
Foreign public documents used before the notary need an apostille and a sworn translation, as set out on the formation pages.
Italian company taxes at a glance
What the company pays itself, by article: the law for 2026. More on what Italian companies pay in tax.
| Tax | Rate | Who it hits | Article |
|---|---|---|---|
| IRES, standard | 24% | resident companies; non-residents on Italian-source income only | Agenzia delle Entrate, IRES |
| IRES, reduced, FY2025 only | 20% | 80% of the 2024 profit to a reserve, investment of not less than EUR 20,000, headcount conditions | L. 207/2024, Art. 1, commi 436-444 |
| IRAP, ordinary | 3.9% | the net value of production, a different base from IRES | D.Lgs. 446/1997 Art. 16 |
| IRAP, sector rates | 4.20% / 4.65% / 5.90% | concession holders / financial intermediaries / insurers | D.Lgs. 446/1997 Art. 16 |
| IRAP, regional variation | up to 0.92 points | set by the region; an ordinary-statute region may cut the rate to zero | D.Lgs. 446/1997 Art. 16 |
| IRAP, surcharges | +2 points | listed ATECO codes, 2026 and 2027 tax periods; banks and insurers, three periods | D.L. 21/2026 Art. 3(1); L. 199/2025 Art. 1(74) |
| IRAP, non-resident | 3.9% ordinary | only for activity in a region for at least three months through a permanent establishment | D.Lgs. 446/1997 Art. 12 |
| Dividends received | 95% excluded | an Italian company receiving dividends | Art. 89(2) TUIR |
| Gains on qualifying holdings (PEX) | 95% exempt | holding from the first day of the twelfth month before the sale, and the other conditions | Art. 87(1) TUIR |
| Shell-company surcharge | +10.5 points IRES | a company failing the revenue test, not in its first tax period | Art. 30 L. 724/1994; D.L. 138/2011 |
Italian company taxes for 2026. The TUIR articles cited carry an end date of 31 December 2026.
Guides of their own: the super-deduction for R&D on protected intangibles and the Italian crypto tax guide.
Money leaving Italy: dividends, royalties and treaty relief
What the company withholds when it pays its foreign group, and the paper that lowers it. See S.r.l. dividends tax in Italy and, for a US parent, what the treaty protects a US shareholder from.
| Payment | Default withholding | Route that lowers it | Conditions and paper | Article |
|---|---|---|---|---|
| Dividend to a parent outside the EU/EEA | 26% final | a treaty rate; refund of foreign tax up to 11/26 of the withholding | treaty form and residence certificate | Art. 27(3) D.P.R. 600/1973; D.L. 66/2014 Art. 3(1) |
| Dividend to an EU/EEA company | 1.20% final | none needed | resident and taxed in the EU/EEA; holding not connected with an Italian PE | Art. 27(3-ter), replaced by D.L. 38/2026 Art. 11(2) from 1 January 2026 |
| Dividend under Parent-Subsidiary | none at source | the parent's request | 10% holding, held for one year, certificate of the foreign tax authority, in hand by the payment date | Art. 27-bis D.P.R. 600/1973 |
| Royalties to a non-resident | 30% final | a treaty rate | treaty form and residence certificate | Art. 25(4) D.P.R. 600/1973 |
| Interest and royalties to an EU associated company | exempt | Directive 2003/49/EC | its conditions and certification | Art. 26-quater D.P.R. 600/1973 |
| Any treaty claim | as above | unilateral models of 10 July 2013; agreed forms for Germany, Portugal, the United Kingdom, the United States, Sweden and Switzerland | a residence certificate from the claimant's own tax authority | Agenzia delle Entrate, treaty forms |
Withholding on money paid out of Italy, 2026. The D.P.R. 600/1973 texts cited end on 31 December 2026.
- Withholding
- 26% final
- Basis
- Art. 27(3) D.P.R. 600/1973; D.L. 66/2014
- Withholding
- 1.20% final
- Basis
- Art. 27(3-ter)
- Withholding
- None at source
- Conditions
- 10% holding, one year, the foreign authority's certificate, request before payment (Art. 27-bis)
- Withholding
- 30% by default (Art. 25(4))
- Lower by
- A treaty, or the Art. 26-quater directive route
Problems we solve
- The board meets abroad, or in Italy, by habit
Residence turns on three alternative criteria, each for most of the tax period (Art. 73(3) TUIR). We map where decisions are actually taken.
- A foreign holding run from Italy, or an agent who signs here
A foreign holding controlled from Italy, or run by a mostly resident board, is presumed resident unless it proves otherwise (Art. 73(5-bis) TUIR); an agent who habitually concludes contracts creates a PE (Art. 162 TUIR). More on foreign companies resident in Italy.
- The parent loses 26% it expected to receive gross
Nothing is withheld at source when the parent holds 10% for one year, holds its tax authority's certificate and asks before payment (Art. 27-bis D.P.R. 600/1973). We check each condition before the first dividend.
- The IRAP rate is not the national one
Sector rates, regional variation of up to 0.92 points and a 2-point surcharge for listed ATECO codes move the 3.9% rate (IRAP 2026 instructions; D.L. 21/2026). We read the company's line.
- A holding with assets and little revenue
From its second tax period, a company that fails the Art. 30 L. 724/1994 revenue test is taxed on a deemed minimum income, with IRES 10.5 points higher. We run the test at each year end.
Is money about to leave the Italian company?
The paper for a lower withholding must be in hand by the payment date. Tell us what is paid, to whom and when.
Why work with us
From our practice
We gather the group chart and board facts before the deed, chase the parent's certificate abroad, and keep one calendar with the bookkeeper and the intermediary.
Federica Conti leads tax and compliance coordination in Rome: ten years on foreign-owned Italian companies, in Italian, English and French.
We hold no protected title, transmit no return and promise no ruling or treaty outcome.
Frequently asked questions
Do you file the company's tax returns yourselves?
No. We prepare the planning input and coordinate the calendar. Transmitting a return to the Agenzia delle Entrate for a client is open only to the closed list of authorised intermediaries in Art. 3(3) D.P.R. 322/1998, so the return is sent by an enrolled intermediary the company appoints, or by the company itself online.
Are you an English-speaking accountant or commercialista?
No. We give tax advice and coordinate in English, from Rome, and claim no protected professional title: the accounting titles are protected in Italy. The company's returns are signed by the company and transmitted by the company itself or by an enrolled intermediary it appoints, as Art. 3(3) D.P.R. 322/1998 requires.
Will you tell us which structure or route to choose?
We set out each option with the conditions the statute attaches to it: the financial year end, who sits on the board and where it meets, where the parent is resident, and the Parent-Subsidiary holding conditions. The choice stays with the company and its own advisers, and we talk it through with them.
What does tax advice cost?
Pricing is on request. What drives the work is the shape of the group, how many payments leave Italy and under which route, and whether a residence or permanent-establishment question is open. The taxes and withholdings themselves are set by statute, and this page shows each one with its article.
Can you run payroll as well?
Payroll is a reserved activity in Italy under L. 12/1979 Art. 1: an enrolled consulente del lavoro handles employees' formalities, and we coordinate that professional on a separate service. The labour side has guides of its own: the basics of Italian employment law and the severance fund every Italian employer accrues.
What taxes does an Italian S.r.l. owned from abroad pay on its profit?
IRES at 24% and IRAP at the ordinary rate of 3.9%, on different bases. Some sectors pay IRAP at 4.20%, 4.65% or 5.90%, regions may move the rate by up to 0.92 points, and companies in listed ATECO codes pay 2 points more in the 2026 and 2027 tax periods (D.L. 21/2026).
Is the 20% IRES rate still available?
It applied to the FY2025 period only, where 80% of the 2024 profit was placed in a reserve and the investment, headcount and hiring conditions were met, with an investment of not less than EUR 20,000 (L. 207/2024, Art. 1, commi 436-444). A company formed now pays IRES at the standard 24%.
When are the first returns and payments due?
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 falls on a Saturday. For a calendar year, the balance and first advance are paid by 30 June and the second advance by 30 November, on F24.
What withholding applies when the Italian company pays dividends to its foreign parent?
26% by default, as a final withholding. A company resident and taxed in an EU or EEA State bears 1.20% within the conditions. Nothing is withheld at source under the Parent-Subsidiary route: a 10% holding held for one year, a certificate from the parent's tax authority and a request before payment (Art. 27-bis D.P.R. 600/1973).
And on royalties paid to the foreign group?
Royalties paid to non-residents carry a 30% final withholding on the taxable part by default, under Art. 25(4) D.P.R. 600/1973. A double tax treaty can reduce it, and payments to an associated company in another EU State can be exempt under the Interest and Royalties Directive route of Art. 26-quater, on its conditions and certification.
How does a non-resident claim a treaty rate on Italian income?
On the Agenzia delle Entrate's forms: the unilateral models of the Provvedimento of 10 July 2013, or the agreed forms that remain for Germany, Portugal, the United Kingdom, the United States, Sweden and Switzerland. Each claim is supported by a residence certificate issued by the claimant's own tax authority.
Are dividends and gains the Italian company receives taxed in full?
No. 95% of dividends received is excluded from the taxable base (Art. 89(2) TUIR), and gains on qualifying holdings are 95% exempt after twelve months and the other participation exemption conditions (Art. 87 TUIR). D.L. 38/2026 restored both in full from 1 January 2026. More in the Italian capital gains tax guide.
Can running the company from abroad change where it is tax resident?
An Italian company is tested on three alternative criteria, each for the greater part of the tax period: registered office, place of effective management and principal ordinary management (Art. 73(3) TUIR). A foreign holding run from Italy is presumed resident unless it proves otherwise, and the Agenzia says residence cannot be settled by an advance ruling.
When does selling into Italy without a company create a permanent establishment?
When the foreign enterprise works through a fixed place of business in Italy, a construction or installation site lasting more than three months, or a person who habitually concludes contracts for it (Art. 162 TUIR). A permanent establishment files a VAT declaration within 30 days and owes IRAP once active in a region for three months.
What changed in 2026 for a company owned from abroad?
From 1 January 2026, D.L. 38/2026 Art. 11 restored the 95% dividend-exclusion and participation exemption regimes in full and re-enacted the 1.20% rate for EU and EEA companies at the same level. Companies in listed ATECO codes pay 2 IRAP points more in the 2026 and 2027 tax periods.
Talk to us about your company's tax year
One review of the company's taxes, its payments abroad and its dates, before the year closes.