Itàlia: Entorn econòmic
Interest expense is fully tax-deductible up to the amount of interest income. Interest expense in excess is deductible at up to 30% of the gross EBITDA, and the part in excess of the yearly limitation is carried forward in the following five fiscal years. Specific rules apply to the deduction of bad debts. Travel expenses incurred within the municipality are tax-deductible up to 75% (however, VAT is fully deductible).
An "allowance for corporate equity” (ACE) is available, consisting of a deduction equal to the net increase in the equity employed, multiplied by a rate determined each year (1.3% in 2023). The deduction is available each year, provided the equity increase is not diminished. Nevertheless, the ACE allowance was repealed as of 2024.
Company car expenses can be deducted up to 20% for cars that are not assigned to employees or are granted to employees solely for business use, and 70% if they are destined to employees for both business and private purposes. Mobile and landline telephones expenses are deductible up to 80%.
Deductions are available for charitable contributions. Meals and lodging expenses incurred within the municipality are deductible up to 75% of the expense incurred.
Losses may be carried forward and offset against corporate taxable income; however, 20% of taxable income in any year cannot be offset by carried-forward losses and is subject to corporate tax. Losses incurred in the first three tax periods may be carried forward to be offset against 100% of taxable income if these losses are linked to a new business activity. The carryback of losses is not permitted.
Incentives are available as capital grants, easy-term loans, or tax credits. Some are granted automatically if requirements are met, while others require evaluation or negotiation.
Italian companies and branches of foreign companies can apply for the patent box regime, offering a 110% super tax deduction (210% overall) for R&D expenses on eligible intangible assets, starting from FY 2021. A tax credit for new investments in tangible and intangible assets is available through FY 2025, with varying rates based on the "Industry 4.0" plan. R&D, innovation, and design tax credits are available through FY 2025 or FY 2031, depending on the investment type, and can offset corporate tax liabilities in three annual installments.
In FY 2024, a temporary incentive allows a 120% corporate tax deduction for new hire labor costs, up to 130% for specific employee categories, if conditions are met. The 2024 budget law introduced a 50% exemption from IRES and IRAP for income from activities relocated to Italy from non-EU/EEA states, valid for the relocation year and the next five years. This incentive excludes activities conducted in Italy within the prior 24 months and includes a recapture mechanism if activities are moved abroad during or within five years after the incentive period (ten years for large enterprises).
A Digital services tax (DST) was introduced in 2020. It is levied on taxpayers that, at a group level, have annual global turnover over EUR 750 million in the previous calendar year and annual revenue from digital services rendered in Italy of over EUR 5.5 million in the previous calendar year, irrespective of their tax residency. The rate is 3% of gross revenue net of VAT or indirect taxes. Companies subject to the tax must maintain monthly records of relevant transactions.
Social security contributions depend on the activity performed by the company, the number of employees, and the employee's position. For employers, the contribution is generally around 30%.
Italian shipping companies that are tax residents, as well as non-resident shipping companies that operate in Italy through a permanent establishment, may meet the requirements to opt for the tonnage tax regime.
Italy | OECD | United States | Germany | |
Number of Payments of Taxes per Year | 14.0 | 10.1 | 10.6 | 9.0 |
Time Taken For Administrative Formalities (Hours) | 238.0 | 163.6 | 175.0 | 218.0 |
Total Share of Taxes (% of Profit) | 59.1 | 41.6 | 36.6 | 48.8 |
Source: Doing Business, Latest available data.
EUR 0 - 28,000 | 23% |
EUR 28,001 - 50,000 | 35% |
EUR 50,001 and over | 43% |
Municipality Tax | 0 to 0.9% |
Regional Tax | 1.23% to 3.33% |
Self-Employed Resident Individuals | Flat tax of 15% on up to EUR 85,000 of business and professional gross income, without being subject to additional regional and municipal taxes (conditions apply) A reduced flat tax of 5% applies for new activities (conditions apply) |
In addition to the classic system of tax deductions provided for by the Italian Tax Code, Law no. 21/2020 and the Italian Budget Law for FY 2021 introduced an extra mechanism for reducing taxes, consisting of the recognition of a sum by way of additional treatment. The sum does not contribute to the formation of income and therefore constitutes a net amount, and is equal to EUR 1,200 per year (FY 2024) in the case of incomes not exceeding EUR 15,000. For annual income between EUR 15,001 and 28,000, the amount of the additional treatment needs to be prorated on the basis of the Italian net income tax.
Individuals transferring their tax residency to Italy may elect to pay a flat substitutive tax of EUR 100,000. This tax covers foreign income, excluding capital gains on qualified participation in the first five years, foreign real estate, financial investments, and exempts from financial monitoring obligations. Family members can also elect for a flat tax of EUR 25,000 on non-Italian income. Eligibility requires non-Italian tax residency for at least nine of the ten years before the transfer.
Withholding taxes may be reduced under an international tax treaty.
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Actualitzacions: July 2024