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Company Formation · Italy

Set up a company in Italy.

The EU's third-largest economy. The Patent Box super-deduction at 110% on R&D for IP. One of the widest tax-treaty networks in Europe. The right base for manufacturing, design, luxury goods, food & wine, and Mediterranean market access.

24% IRES Corporate Tax
110% Patent Box (R&D)
103+ Tax Treaties
EU 1957 Founding Member
17 Years Founded 2009 · UK Reg. 11575770
100+ Jurisdictions Covered
40+ Senior Consultants Globally
20+ Sectors Served
48 Hours Quote Turnaround
At a Glance

Italy — the essentials.

Capital
Rome (Roma)Milan is the commercial centre
Population
~58.9 millionEU founding member (1957)
Currency
Euro (€)Eurozone founding member
Official Language
ItalianEnglish standard in international business
Time Zone
CET (UTC+1)CEST in summer
Economy
3rd largest in EUG7 industrial base · Eurozone
Legal System
Civil lawCodice Civile · continental tradition
Corporate Register
Registro ImpreseCamera di Commercio · registroimprese.it
Why Italy

Six reasons clients choose Italy.

The EU's third-largest economy and a G7 industrial base. The Patent Box super-deduction, the Impatriati relocation regime, and one of the widest tax-treaty networks in Europe make Italy genuinely competitive for the right business.

3rd EU

EU's third-largest economy

Italy is the EU's third-largest economy and a G7 industrial base. ~58.9 million population, deep manufacturing capability, world-leading luxury, design, food & wine, and pharma sectors. A genuinely large addressable home market.

110%

Patent Box: 110% R&D super-deduction

The cost-based Patent Box regime grants a 110% super-deduction on R&D costs for qualifying IP — patents, copyrighted software, designs, and models — in both IRES and IRAP. Net tax benefit ~31% of qualifying R&D costs. Five-year irrevocable election, renewable.

50%/€100k

Impatriati & HNWI flat-tax regimes

The Impatriati regime grants a 50% income exemption for up to 5 years (extendable to 10) for foreign relocators. The HNWI flat-tax regime caps tax on global non-Italian income at €100,000 per year for up to 15 years. Two of the most generous lifestyle relocation regimes in the EU.

103 DTTs

103+ double tax treaties

One of the widest tax-treaty networks in Europe — covering practically every major economy and most emerging markets. Combined with the EU passport and full Parent-Subsidiary Directive access, makes Italy a credible holding location for cross-border groups.

Manufacturing & engineering depth

Italy is the EU's second-largest manufacturer after Germany. World-class machinery, automotive, fashion, design, food & wine, leather, and pharma clusters. Exceptional skilled engineering workforce and a deep tier-2/tier-3 supplier ecosystem.

Hyper-depreciation incentive (NEW 2026)

The 2026 Budget Law introduced a hyper-depreciation incentive replacing Transition 4.0 / 5.0 tax credits. Enhanced depreciation on qualifying capital goods and self-consumption renewable energy assets, for investments from January 2026 to September 2028. Material capex tax shield.

Business Structures

Choose the right vehicle — six options.

Most international clients use the SRL for SMEs and foreign-owned subsidiaries, the SRLS for ultra-light setups, or the SPA for larger / IPO-track businesses. We will tell you straight which one fits your situation, and why.

Structure Min. Capital Liability Best for Formation
SRLSocietà a Responsabilità Limitata · Limited Liability Company Most Used
€10,000
25% paid up at incorporation
Limited to share capital The default choice for SMEs, foreign-owned subsidiaries, holdings, and operating businesses. Flexible governance, full liability protection. 3–5 weeks
SRLSSocietà a Responsabilità Limitata Semplificata · Simplified LLC
€1 – €9,999
Simplified setup, lower notary fees
Limited to share capital Ultra-light SRL for sole founders or small partnerships. Founders must be individuals (no corporate shareholders). Standard articles, no customisation. 2–3 weeks
SPASocietà per Azioni · Joint-Stock Company
€50,000
25% paid up at incorporation
Limited to share capital Larger businesses, IPO-track companies, regulated industries, banks/insurance subsidiaries needing freely transferable shares and formal governance. 5–8 weeks
SASSocietà in Accomandita Semplice · Limited Partnership
None Mixed (general / limited) Investor / operator structures where general partners manage and limited partners provide capital with capped liability. 2–4 weeks
SNCSocietà in Nome Collettivo · General Partnership
None Unlimited, joint & several Two or more partners running an active business together; tax-transparent for IRES purposes (income flows to partners), still subject to IRAP. 2–3 weeks
BranchFiliale · Branch of foreign company
None Parent company liable Foreign-headquartered groups establishing local presence without separate legal entity. Faster to set up; parent carries direct liability. 3–5 weeks
Tax & Compliance

The numbers that matter.

Headline figures every founder, finance director or international operator should know before they incorporate.

24%
IRES Corporate Tax
Standard flat rate on worldwide income for Italian-resident companies. Imposta sul Reddito delle Società, applied to net taxable income from the company's financial statements as adjusted by Italian tax rules.
+3.9%
IRAP Regional Tax
Regional production tax (Imposta Regionale sulle Attività Produttive) on value-added. Standard 3.9% with regional variation of ±0.92% (so 2.98% to 4.82%). Higher rates for banks (4.65%) and insurance (5.90%).
22%
VAT (IVA Standard)
Reduced rates of 10% (food, hotels, certain services), 5% (some social services and basic foodstuffs), and 4% super-reduced (basic foods, books, agricultural products). Mandatory SDI e-invoicing platform.
110%
Patent Box (R&D)
Cost-based Patent Box: 110% super-deduction on qualifying R&D costs for patents, copyrighted software, designs, and models — for both IRES and IRAP. Net tax benefit ~31% of R&D costs. 5-year irrevocable election, renewable.
95%
Dividend Exemption
95% of qualifying dividends excluded from IRES taxable base. From 1 Jan 2026, requires ≥10% direct or indirect participation. EU corporate recipients qualify for 1.2% WHT or 0% under the Parent-Subsidiary Directive.
yrs
Loss Carry-Forward
Indefinite loss carry-forward, but offset capped at 80% of taxable income in any given year. The 80% cap does NOT apply to losses incurred in the company's first three years of activity — full use available.
NEW 2026
Hyper-Depreciation
2026 Budget Law replaced Transition 4.0/5.0 tax credits with a hyper-depreciation incentive on qualifying capital goods and self-consumption renewable assets. Investments from January 2026 to September 2028. Material capex tax shield.
SDI
E-Invoicing Mandatory
Sistema di Interscambio: every B2B and B2G invoice must transit through the Agenzia delle Entrate's central platform. Compulsory for all SRL, SPA, and entities holding a Partita IVA. We set up SDI integration as part of formation.
Pillar Two minimum tax: Italy has implemented the OECD/EU 15% global minimum effective tax for multinational groups with consolidated turnover above €750 million, effective FY 2024 onwards, via the Income Inclusion Rule, Undertaxed Profits Rule, and a Qualified Domestic Minimum Top-Up Tax (QDMTT). Most SMEs and growth-stage businesses are not in scope.
Formation Process

From decision to trading entity.

A realistic seven-step path. Most international clients with an SRL are operational within 3–5 weeks; an SPA typically runs to 5–8 weeks given the heavier capital and governance requirements.

01

Discovery & structure design

Confirm the right vehicle (SRL, SRLS, SPA, SAS, branch), shareholding, directorships, registered seat (regional IRAP analysis), and tax position. Patent Box and Impatriati eligibility assessed where relevant.

Week 1
02

Statuto & atto costitutivo drafting

Articles of Association (statuto) and deed of incorporation (atto costitutivo) drafted — in Italian for filing, with English translation for foreign shareholders. Specifies share structure, governance, directorship, and registered seat.

Week 1–2
03

Notarisation (mandatory for SRL/SPA)

Articles executed before an Italian notary (notaio). The notaio handles publication and electronic filing with the Registro Imprese. Notary fees are a meaningful cost line in Italian incorporation — we shop them.

Week 2–3
04

Registro Imprese filing

Registration with the Italian Business Register (Registro Imprese) via the local Camera di Commercio and registroimprese.it. Company receives its corporate registration number and Codice Fiscale (corporate tax code).

Week 2–3
05

Agenzia delle Entrate registration

Registration with Agenzia delle Entrate for Codice Fiscale and Partita IVA (VAT number), including EU VAT-ID for cross-border trade. SDI e-invoicing platform setup is mandatory from day one.

Week 3–4
06

Bank account & capital deposit

Italian bank account opened. For SRL, 25% of capital paid in. For SPA, 25% paid in. UBO declaration filed via the Italian Central UBO Register. The longest single step for international clients with non-EU shareholders.

Week 3–5
07

INPS, INAIL & sectoral licences

Registration with INPS (social security) and INAIL (workplace insurance) if hiring. Sector-specific licences via Camera di Commercio or relevant authority. Patent Box election filed within first tax period if applicable.

Week 4–5
What We Handle

A single partner. End to end.

You get one senior point of contact at Grant & Graham. Behind that, a vetted local network of notaries, banks, accountants, and lawyers we have worked with for years.

01 · ADVISORY

Structure & tax design

Choosing the right vehicle (SRL, SRLS, SPA, SAS, branch), shareholding, registered seat (regional IRAP analysis), and tax position. Patent Box and Impatriati relocation modelling at the structure design stage where relevant.

02 · LEGAL

Statuto & notaio

Drafting Articles of Association (statuto) and deed of incorporation (atto costitutivo) in Italian and English, coordinating Italian notaio execution, and shopping notary fees across our partner network.

03 · FILING

Registro Imprese & Agenzia delle Entrate

Camera di Commercio / Registro Imprese filing, Agenzia delle Entrate registration for Codice Fiscale and Partita IVA, EU VAT-ID, SDI e-invoicing setup, UBO Register, and ongoing compliance filings.

04 · BANKING

Bank account introduction

Direct introductions to leading Italian and international banks operating in Italy. We compress account-opening timelines for foreign clients and coordinate KYC documentation upfront, including FATCA / CRS reporting.

05 · FINANCE

Commercialista network

Bookkeeping, payroll, monthly/quarterly VAT, annual financial statements, IRES/IRAP returns, F24 payment scheduling, and quarterly advance payments through our partner commercialisti in Milan, Rome, and Turin.

06 · PEOPLE

HR, employment & relocation

Employment contracts under the Statuto dei Lavoratori, INPS social security and INAIL workplace insurance registration, work permit and Single Permit support for non-EU hires, and Impatriati relocation packages.

Best Fit When…

Italy is the right answer for specific situations.

Not the lowest-tax jurisdiction in the EU, and not the lightest-touch on labour cost. The right call when the business model genuinely benefits from being in Italy — one of these scenarios.

You operate or invest in EU manufacturing

Italy is the EU's second-largest manufacturer after Germany. Deep machinery, automotive, electronics, and pharma clusters with mature tier-2/tier-3 supplier networks. Northern Italian industrial corridor (Milan–Turin–Bologna) is among the best in Europe.

You are luxury, design, fashion, or food & wine

Italy's "Made in Italy" brand is genuinely globally premium across luxury goods, design, fashion, leather, and food & wine. The depth of artisan supply chain, design talent, and DOP/DOC certification framework is irreplaceable for these sectors.

You want a Mediterranean / Southern European base

Italy sits at the heart of the Mediterranean, with strong shipping, port, and air connectivity. Genuine commercial bridge between Northern Europe, the Balkans, North Africa, and the Middle East. ~58.9 million domestic consumer market, plus EU passport.

You are Patent Box / IP-led / R&D-heavy

The 110% Patent Box super-deduction on R&D for IP delivers a net tax benefit of ~31% of qualifying costs. Combined with the indefinite loss carry-forward and the new 2026 hyper-depreciation, exceptionally favourable for innovation-led businesses.

You are a HNW relocator (Impatriati or HNWI flat tax)

The Impatriati regime grants 50% income exemption for 5 years (extendable to 10) for foreign professionals relocating to Italy. The HNWI flat-tax regime caps tax on global non-Italian income at €100,000 per year for up to 15 years. Two of the most generous lifestyle relocation regimes in the EU.

You need a wide treaty network

Italy's 103+ double tax treaties cover practically every major economy and most emerging markets. Combined with full Parent-Subsidiary Directive access and the 95% dividend exemption, makes Italy a credible holding location for cross-border groups with global subsidiary footprints.

Cost & Timeline Planner

Get an estimate in 30 seconds.

Three quick questions. We will give you a realistic cost range and timeline for your situation, and route the answers straight into a fixed-price quote request.

Step 1 of 3
01 · Structure
Which company structure are you considering?
02 · Setup
How is the shareholding structured?
03 · Services
What do you need from us?
Estimated for your situation
All-in cost (one-off)
Timeline to operational
Recommended structure
Estimate only. Final quote depends on specific scope, sector requirements, and any sector-specific licences. Includes Italian notaio, Registro Imprese filing, Agenzia delle Entrate registration, SDI e-invoicing setup, INPS/INAIL where applicable, and Grant & Graham senior advisory at €250/hour.
Frequently Asked

The questions we get asked most.

How long does it take to set up an SRL in Italy?
Typically 3–5 weeks from instruction to a fully operational entity with bank account, Registro Imprese registration, and Agenzia delle Entrate tax/VAT registration. The notary step (mandatory before an Italian notaio) and the bank account opening for non-EU shareholders are normally the longest single steps. An SPA typically runs to 5–8 weeks given the heavier capital and governance requirements; an SRLS (Simplified LLC) can complete in 2–3 weeks.
What's the difference between an SRL, an SRLS, and an SPA?
The SRL (Limited Liability Company) is the workhorse vehicle — €10,000 minimum capital, flexible governance, full liability protection. The SRLS (Simplified LLC) is an ultra-light variant for sole founders or small partnerships with capital between €1 and €9,999; founders must be individuals (no corporate shareholders), and articles must follow a standard template. The SPA (Joint-Stock Company) requires €50,000 minimum capital, formal board governance, and is the right choice for larger businesses, IPO-track companies, and regulated industries.
Do shareholders or directors need to be Italian or EU residents?
No. Foreign nationals and non-EU residents can be both shareholders and directors of an Italian SRL or SPA (the SRLS does require individual rather than corporate shareholders). There is no nationality or residency requirement. For a smooth bank account opening and a credible local presence, having at least one director with EU presence is helpful. Non-EU directors and senior staff can apply for residence permits including the Italian Investor Visa or Self-Employed Visa.
How does the Patent Box actually work in 2026?
The cost-based Patent Box regime grants a 110% super-deduction on R&D costs incurred either directly or through outsourcing to universities or independent research institutes — for qualifying IP including copyrighted software, patents, designs, and models. The deduction applies for both IRES and IRAP, producing a net tax benefit of approximately 31% of qualifying R&D costs. The election lasts five fiscal years, is irrevocable, and is renewable. R&D costs incurred with related parties are not eligible.
What's IRAP and how is it different from IRES?
IRAP (Imposta Regionale sulle Attività Produttive) is a regional tax on the value generated by productive activities in Italy. The standard rate is 3.9% with regional variation of ±0.92% (so 2.98% to 4.82%); banks pay 4.65% and insurance companies 5.90%. The IRAP base differs materially from IRES — it is closer to gross margin and excludes most personnel costs from deduction (with carve-outs for permanent contracts and some other categories). Italy is gradually working to replace IRAP via the 2023 tax reform delegation, but no firm timeline is in place yet.
What ongoing compliance does an Italian company face?
Annual financial statements filed with the Registro Imprese, IRES and IRAP returns by 31 October of the following year, monthly or quarterly VAT returns (quarterly available for service businesses below €400k turnover), monthly SDI e-invoicing, IRES/IRAP balance payment by end of the 6th month following year-end, two advance payments (40% by 30 June, 60% by 30 November), monthly INPS social security filings if employing staff, INAIL annual premium, and the Camera di Commercio annual fee. We package this as an ongoing service for international clients.
How They Compare

Italy vs France vs Germany.

The three biggest EU economies. A side-by-side comparison on the numbers international corporates actually weigh.

  Italy France Germany
Primary Vehicle SARLSAS / SA for larger setups GmbHUG / AG for smaller / larger
Min. Share Capital €1No meaningful minimum on SARL €25,000€1 for UG variant
Corporate Tax 25%Standard CIT, no regional addition ~30%~15.8% CIT + ~14.0% trade tax (Gewerbesteuer)
Formation Time 2–4 weeksNotary not required for SARL 4–6 weeksNotary mandatory; bank account often the bottleneck
Standout Feature Inventeur regime & CIR30% R&D tax credit; strong startup ecosystem EU's largest marketIndustrial powerhouse; Mittelstand depth
Best Fit Consumer brands, luxury, R&D, French market access Industrial, automotive, B2B, DACH market access
Watch Out For Higher labour costsPlus complex collective-bargaining environment Trade tax variabilityGewerbesteuer rate set by municipality
Comparison data verified April 2026. Tax rates are headline figures — effective burdens vary by deductions, allowances, and structure. We can model the right answer for your situation in 48 hours.
Start the Conversation

Ready to set up in Italy?

Tell us what you are trying to do and we will come back inside 48 hours with a fixed-price quote and timeline. No pressure to commit — just a clear answer from a senior adviser.