Corporate Income Tax - Ires

Latest update: 24/12/2024

Relevant Tax Rate

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 and private entities resident in Italy, including consortia, trusts, collective savings investment undertakings and non-commercial entities (non-profit organisations);
• companies and bodies of all kinds, including trusts, not resident in Italy, for income generated in Italy only.

The following shall be considered to be resident for tax purposes in Italy:

• companies and entities having their registered office or effective place of management or principal place of business in Italy for most of the tax period
   
• collective savings investment undertakings established in Italy

• unless proven otherwise, trusts and similar institutions set up in countries or territories other than those that allow an adequate exchange of information (IT) with Italy, if at least one of the settlors and at least one of the beneficiaries of the trust are tax residents in Italy;

• unless proven otherwise, trusts set up in countries or territories other than those that allow an adequate exchange of information (IT) when, after they are set up, an entity resident in Italy makes an allocation to the trust which amounts to the transfer of ownership of immovable property or the creation or transfer of rights in rem in immovable property, including through shares, and restrictions on the use thereof.

Exemptions

Income from collective savings investment undertakings based in Italy and those based in Luxembourg is exempt from corporation tax in the cases provided for under legislation (Article 73(5-quinquies) of the Consolidated Law on Income Tax (TUIR)) (IT).