The soAn additional CIT rate of 5.5% was introduced during 2008 charged on oil, gas and electricity
industries in relation to extra profit generated from exceptional high oil prices. It is explicitly forbidden for
those firms to shift the tax on prices, under the surveillance of the Energy Authority.
Since 2009 the rate was increased to 6.5%.
Law Decree 138/2011 further increased the rate from 6.5% to 10.5% for the tax periods from 2011 to
2013. The Robin tax is now charged also on companies that produce electricity through the use of
renewable sources of energy.
Starting from 2014, the Robin tax is charged, as before, at 6.5% on all taxpayers.
Starting from 12th February 2015, the Robin Tax is no longer applied, having been declared
unconstitutional by the Italian Constitutional Court.
The new Allowance for Corporate Equity (ACE) system of taxation
Starting from 1st January 2012, Italy introduced a variant on the Italian corporate income tax that is
the allowance for corporate equity (ACE) system of taxation, now applied to new injections of equity funds
in Italian enterprises (both in the form of money given by shareholders and as accumulated profits).
According to the new system, firms are allowed to deduct a notional return on their new injections of
equity, defined as the product of the amount of new equity funds (with reference to the equity stock at 31st
December 2010), with a notional interest rate that, according to Italian rules, is equal to 3% for the years
from 2011 to 2013 (after that term, the notional interest rate to be applied to the injections of new equity
will be determined each year by the Ministry of Economy and Finance).
The tax benefits provided by the ACE system of taxation were augmented by Law n. 147/2013 (taking
effect from 1st January 2014), in the form of an increase of the notional interest rate applied to the amount
of new injections of equity funds;
4% for the tax period in progress on 31st December 2014;
4.5% for the tax period in progress on 31st December 2015;
4.75% for the tax period in progress on 31st December 2016.
After 2016, the notional interest rate to be applied to the injections of new equity will be determined
each year by the Ministry of Economy and Finance, always within 31st January of the year of reference.
Corporate income tax is paid by legal entities and non-resident permanent establishments for their
income. The corporate income is taxed at a flat rate. The tax rate was 25 per cent until 2001 and then it
gradually decreased to 15 per cent in 2004 where it has remained ever since.
Tax Rates 2016
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Basic rate 15%
Withholding tax (payments made by residents and non-resident permanent
Corporate income tax payers are the performers of economic activity (residents):
institutions financed from the State budget, whose income from economic activity is not provided
for in the State budget,
institutions financed from local government budgets whose income from economic activity is
not provided for in the State budget.
foreign commercial companies, natural persons and other persons (non-residents) and permanent
establishments of non-residents.
Main corporate income tax reliefs and exemptions in 2014 were:
losses carried forward from previous years;
applying increased rate of depreciation for tax purposes;
amount of dividends receivable from another payer or paid to non-residents (except low-tax or
tax-free state or territory);
allowance for purchasing of new production technology equipment;
tax relief for donors.
Corporate income tax is paid to the central government budget. The taxation period is an accounting
year of a taxpayer.