At a glance

Corporate Income Tax Rate (herinafter: 'CITR') 

Tax rate applied on capital gains 27,5% (a)
Tax rate applied on branch profits 27,5% (b)

Other taxes (e.g. local or state tax - herinafter: 'IRAP')      


Withholding taxes (standard rates)

on dividends 27%
on branch profit remittance N/A
on interest 12,5-27% (e) 
on royalties 22,5%
Tax losses  
Loss carry back period N/A
Loss carry forward period 5 years
Tax Consolidation Option  
Italian Group yes
WorldWide Group yes

Criminal proceedings in respect of

CITR, IRAP and/or VAT non compliance        

yes (f)
Option for other EU taxation yes (g)
Holding regime yes (a)
VAT Unit yes
Controlled Foreign Companies Rules yes

a) Pex Regime from qualified subsidiaries: ordinary CITR rate on 5% only of the capital gain/dividends

b) Capital Gains can be taxable in 5 years

c) In some regions the basis rate is increased to 4,05%; other specific rules for special-status regions

d) Subject to Double Treaty reduction rate or to UE Parent - Subsidiary Directive, nil withholding tax

e) Subject to Double Treaty reduction rate or to UE Interest and royalty payments Directive, nil withholding tax

f)  Subject to limitations

g) An Italian newly incorporated company hold by a non resident shareholder can choose the submission to another UE Tax law,

    different from the Italian one


Italy (Italian: Italia), officially the Italian Republic, is a country located partly on the European Continent and partly on the Italian Peninsula in Southern Europe and on the two largest islands in the Mediterranean Sea, Sicily and Sardinia. Italy shares its northern, Alpine boundary with France, Switzerland, Austria and Slovenia. The independent states of San Marino and the Vatican City are enclaves within the Italian Peninsula, and Campione d'Italia is an Italian exclave in Switzerland. The territory of Italy covers 301,338 km² and is influenced by a temperate seasonal climate. With 60.4 million inhabitants, it is the sixth most populous country in Europe, and the twenty-third most populous in the world. Italy's capital, Rome, was for centuries the political centre of Western civilisation as the capital of the Roman Empire. Modern Italy is a democratic republic. It has been ranked the world's eighteenth most-developed country and its Quality-of-Life Index has been ranked in the top ten in the world. Italy enjoys a very high standard of living, and has a high nominal GDP per capita. It is a founding member of what is now the European Union and North Atlantic Treaty Organization. Italy is also a member of the G7, G8 and G20. It has the world's seventh-largest nominal GDP, tenth highest GDP (PPP) and the sixth highest government budget in the world. It is also a member state of the Organisation for Economic Co-operation and Development, the World Trade Organization, the Council of Europe, the Western European Union and the United Nations. (Source: Wikipedia)


CTA Members in Italy

Paolo Troiano Paolo Troiano
Telephone: + 39 (0)2 7628 0824 E-Mail:
Walter Pugliese Walter Pugliese
Telephone: +39 (0)2 36755000 E-Mail: