Corporate Tax Filing in Italy for Foreign-Owned Companies
The company's yearly returns, prepared for the authorised intermediary who transmits them.
accounting and compliance
For foreign groups and founders with an Italian S.r.l.
Your Italian company's books, accounts, returns and SDI e-invoicing as one yearly calendar, each reserved act placed with the professional the law names.
Electronic books are time-stamped and signed at least yearly (Art. 2215-bis c.c.).
From Milan, for companies across Italy, FormaItalia keeps the books, prepares the accounts, VAT, SDI invoicing and withholding filings, prepares the returns for an authorised intermediary, coordinates payroll and advises on tax. Much of that load is fixed by what has to be decided before the Italian deed is signed.
It serves a foreign group's Italian subsidiary, a founder's S.r.l. run from abroad, or a company acquired by taking over an existing Italian S.r.l. instead of forming one. The accounts format, the audit exposure and the VAT rhythm follow from structuring a group in Italy, so we plan them together.
Eight deliverables of one yearly service. The reserved acts stay with the persons the law names.
Day book (libro giornale), inventory book (libro degli inventari) and the members' and directors' decision books (Arts. 2214, 2478 c.c.), signed at least yearly (Art. 2215-bis c.c.). See digital document retention in Italy.
The bilancio d'esercizio (annual accounts): balance sheet, profit and loss, cash flow and notes (Art. 2423 c.c.), micro, abbreviated or ordinary, plus the XBRL file for the Register of Companies.
Monthly settlement and F24 by the 16th (Art. 1 D.P.R. 100/1998), the quarterly LIPE, the annual return from 1 February to 30 April (Art. 8 D.P.R. 322/1998). First step: our VAT registration for foreign companies service.
SDI (Sistema di Interscambio, the state exchange) e-invoices to Italian counterparties, a duty of every VAT-registered company established in Italy (Agenzia delle Entrate). Parent invoices go as cross-border data, the former esterometro: incoming by the 15th of the next month (Art. 1(3-bis) D.Lgs. 127/2015, to 31 December 2026).
We prepare the Modello Redditi SC (income return) and the IRAP return: IRES 24%, IRAP 3.9%, sector rates 4.20%, 4.65%, 5.90%, with two-point surcharges from 2026 for certain activities (D.L. 21/2026, L. 199/2025); regions may vary them (Agenzia delle Entrate). The company or an Art. 3(3) D.P.R. 322/1998 intermediary transmits. See how an Italian company files its annual tax return, the IRES and IRAP rates.
As withholding agent (sostituto d'imposta): the Certificazione Unica (CU) to recipients and the Agenzia by 16 March, the modello 770 from 15 April to 31 October (Art. 4 D.P.R. 322/1998).
Payroll formalities are reserved unless the employer runs them itself, save the routes the same article opens to small businesses through their trade associations' services and to EU providers (Art. 1 L. 12/1979). We coordinate an enrolled consulente del lavoro: the payroll services page.
Arm's-length prices with the parent (Art. 110(7) TUIR, 2026 text), the Masterfile and Documentazione Nazionale (local file), the participation exemption, PEX (Art. 87 TUIR, 2026 text). See tax advisory Italy, the capital gains tax guide, how a company is taxed on crypto.
Each choice has conditions in law. The table states them; the choice is made with you before the first year closes.
| Decision | Options and their conditions | Basis |
|---|---|---|
| Accounts format | Micro accounts where two of three limits are not exceeded in the first year or for two consecutive years: EUR 220,000 assets, EUR 440,000 revenue, 5 employees; the company moves up after exceeding two of them for the second consecutive year. Abbreviated accounts on the same test at EUR 5,500,000, EUR 11,000,000 and 50. Ordinary accounts above | Arts. 2435-bis, 2435-ter c.c. |
| Control body or auditor | Required on consolidated accounts, on control of an audited company, or when one limit is exceeded for two consecutive years: EUR 4,000,000 assets, EUR 4,000,000 revenue, 20 employees | Art. 2477 c.c., untouched by Art. 9 D.Lgs. 47/2026 |
| Reporting basis | Civil Code and OIC standards within the abbreviated limits; IFRS only in the cases the IFRS decree lists; the group pack is a separate reconciliation | Art. 2 D.Lgs. 38/2005 |
| VAT rhythm | Monthly settlement and payment by the 16th; or computing on the second preceding month, once the bookkeeping is entrusted to a third party and the choice is stated in the first annual return after it | Art. 1(1), (3) D.P.R. 100/1998 |
| Who transmits the returns | The company, with SPID, CIE, CNS or Fisconline/Entratel credentials; or an intermediary on the closed list, after its written undertaking | Art. 3 D.P.R. 322/1998; Agenzia delle Entrate |
| Employees | Payroll formalities run by the employer itself or its own staff, or by an enrolled professional; small businesses may use their trade associations' services, and EU providers need no enrolment | Art. 1 L. 12/1979 |
| Intra-group pricing | Prices at arm's length; a Masterfile and Documentazione Nazionale, declared in the return, protect against the penalty on an adjustment; or no file | Art. 110(7) TUIR (2026 text); Art. 1(6) D.Lgs. 471/1997; Provvedimento 360494/2020 |
Sources: the articles listed, as in force in 2026 (D.Lgs. 471/1997 to 31 December 2026); Agenzia delle Entrate.
A calendar-year S.r.l. filing its FY2025 accounts and returns in 2026. Every date comes from a statute or the Agenzia delle Entrate.
statute a term set by statuteauthority page a 2026 date of the Agenzia delle Entrate
1 February to 30 April
Annual VAT return
16 March
Books charge and the CU
30 April, computed
Accounts presented to the members
30 days after approval
XBRL deposit with the Register of Companies
30 June, or 20 July 2026
Balance and first advance
2 November 2026, then 30 November
Redditi SC and IRAP for FY2025, then the second advance
Every month, by the 16th VAT settlement and F24 payment (Art. 1 D.P.R. 100/1998, statute)
15 April to 31 October the modello 770, a statutory window with no 2026 calendar mark (Art. 4 D.P.R. 322/1998)
A calendar-year S.r.l., FY2025 filed in 2026
The seven decisions in the table above, made as part of the structuring work. No statutory term.
Books kept and signed at least yearly (Art. 2215-bis c.c.); SDI invoices issued and received; data on the parent's invoices by the 15th of the next month.
VAT settlement and F24 payment (Art. 1 D.P.R. 100/1998); the LIPE by the last day of the second month after each quarter (Agenzia delle Entrate).
The annual charge on the corporate books, paid on F24 with code 7085 (Agenzia delle Entrate). The CU to each recipient and to the Agenzia (Art. 4 D.P.R. 322/1998).
The annual VAT return (Art. 8 D.P.R. 322/1998). The directors present the accounts to the members within 120 days of year end, or up to 180 where the deed allows it for a company that draws up consolidated accounts or has particular needs (Arts. 2364(2), 2478-bis(1) c.c.).
The accounts go to the Register of Companies in XBRL, digitally signed (Art. 2478-bis c.c.; Registro Imprese). The directors remain the officers liable for the deposit.
Balance and first advance (40% of a 100% advance base, 50% for ISA taxpayers); 30 days later at 0.40%, or 0.80% on the 2026 ISA date (indici sintetici di affidabilità, compliance scores); where the accounts are lawfully approved after four months, by the last day of the month after approval (Agenzia delle Entrate). A transfer-pricing file, if kept, is signed by the return date.
Redditi SC and IRAP for FY2025, due 2 November because 31 October 2026 is a Saturday; filing opened on 15 April (Agenzia delle Entrate). The 770 within its statutory window, 15 April to 31 October (Art. 4 D.P.R. 322/1998); the second advance by 30 November.
We set out the conditions and the calendar with your directors before the first year closes, and name who performs each act.
FormaItalia prepares and keeps; the persons named here perform the reserved acts. No firm is named or ranked.
At the centre: the company and its directors
They keep the books, draft and present the accounts, and remain liable for the deposit.
The members
approve the accounts
Art. 2478-bis c.c.
An authorised intermediary
transmits the income and IRAP returns, after its written undertaking
Art. 3(3) D.P.R. 322/1998
An enrolled consulente del lavoro
runs the payroll formalities where there are staff
Art. 1 L. 12/1979
A registered revisore legale or audit firm
the statutory audit, where Art. 2477 c.c. applies
Art. 2396-novies c.c.; D.Lgs. 39/2010
A Section A or B member of the Albo
may transmit the XBRL deposit, appointed by the legal representatives
the register of dottori commercialisti and esperti contabili; Art. 31 L. 340/2000
FormaItalia
prepares and keeps the books, accounts and returns, and coordinates the acts above
a coordinator holding no reserved title
No firm is named or ranked.
| Act | Term | Who performs it | State charge | Basis |
|---|---|---|---|---|
| Keep the books | Continuous; kept ten years from the last entry | The company, through its directors; we keep them for it | Not stated here | Arts. 2214, 2220 c.c. |
| Books charge | By 16 March, F24 code 7085 | The company | EUR 309.87, or EUR 516.46 where capital exceeds EUR 516,456.90 | Agenzia delle Entrate |
| Present and approve the accounts | Presented within 120 days from year end; up to 180 where the deed allows it for consolidated accounts or particular needs | The directors draft and present; the members approve | Not stated here | Arts. 2364(2), 2478-bis(1) c.c. |
| Deposit in XBRL | 30 days from approval | The directors are liable; a Section A or B member of the Albo (the register of dottori commercialisti and esperti contabili) appointed by the legal representatives may transmit | EUR 65 stamp duty, EUR 60 secretarial fee and the OIC contribution; no total (Romagna chamber, 2026) | Art. 2478-bis c.c.; Art. 31 L. 340/2000 |
| Income and IRAP returns | Tenth month after year end; FY2025 by 2 November 2026 | The company with Italian credentials, or an Art. 3(3) intermediary, who owes a written undertaking and a copy within 30 days of the deadline | Not stated here | Arts. 2, 3 D.P.R. 322/1998 (2026 text) |
| CU and 770 | 16 March; 15 April to 31 October | The withholding agent, directly or through an intermediary | Not stated here | Art. 4 D.P.R. 322/1998 |
| Payroll formalities | Where there are staff | The employer or its own staff, or an enrolled consulente del lavoro, lawyer, dottore commercialista or ragioniere e perito commerciale | Not stated here | Art. 1 L. 12/1979 |
| Statutory audit | Where Art. 2477 c.c. applies | A registered revisore legale or audit firm | Not stated here | Art. 2396-novies c.c.; D.Lgs. 39/2010 |
| Transfer-pricing file | By the return date, where kept | The legal representative signs, with an electronic signature and time stamp | Not stated here | Provvedimento 360494/2020 |
Sources: Agenzia delle Entrate, books charge; Art. 3 D.P.R. 322/1998; Registro Imprese, deposit of the accounts; MEF register of statutory auditors; Romagna chamber fee table, 2026; the Civil Code articles listed.
The tax articles are the 2026 text; the consolidated income-tax and VAT texts (D.Lgs. 117/2026, D.Lgs. 10/2026) apply from 1 January 2027.
What the owner and the directors give us; the difference between a VAT number and a codice fiscale explains the first two codes.

Five points in a foreign-owned S.r.l.'s compliance year, and how we handle each.
The Italian accounts follow the Civil Code and the OIC standards unless Art. 2 D.Lgs. 38/2005 brings in IFRS. We plan the reconciliation to the group's IFRS or US GAAP pack as a separate deliverable.
One Art. 2477 c.c. limit exceeded for two years, such as EUR 4,000,000 of assets, brings a control body or auditor; abbreviated accounts run to EUR 5,500,000 (Art. 2435-bis c.c.). Our calendar tracks both.
Parent invoices reach the SDI as cross-border data; prices are tested at arm's length, and a declared file keeps the 70% penalty off an adjustment (Art. 1(6) D.Lgs. 471/1997, to 31 December 2026). Royalties: our intellectual property registration service.
Electronic books, the XBRL deposit and the return need a digital signature and Italian credentials, or an authorised intermediary. Which foreign signatures work is checked per file; we promise none.
Dividends to the parent, the owner's own tax and the quotas on succession sit outside the accounts: our dividend tax overview, how Italy taxes a foreign owner, inheritance tax in Italy. Treaties and residence: our Italy-US tax treaty overview, who issues the certificate and how long it takes, a residence route for a company founder.
Tell us the year end, the previous adviser's records and the filings still open; we map the handover into the calendar.
Tax and Cross-Border Compliance Lead, Milan.
FormaItalia holds none of the protected titles; each reserved act is performed by the person named in the table above.
From our practice
before the first year closes we set out the accounts format, VAT rhythm and filing route with the directors, and agree who acts as intermediary, consulente del lavoro and, under Art. 2477 c.c., auditor.
No. Dottore commercialista, esperto contabile, revisore legale and consulente del lavoro are titles tied to public registers (D.Lgs. 139/2005, D.Lgs. 39/2010, L. 12/1979), and FormaItalia claims none of them. Transmitting a client's return, payroll formalities and the statutory audit are reserved to listed persons, whom we coordinate; the sources we have read do not show bookkeeping itself reserved.
The company files online through the Agenzia delle Entrate's services with SPID, CIE, CNS or Fisconline/Entratel credentials. Otherwise an intermediary on the closed list of Art. 3(3) D.P.R. 322/1998 transmits it, after giving a written undertaking. Whether a given foreign signature or electronic ID works is checked for each file, so we promise neither in advance.
An enrolled consulente del lavoro, lawyer, dottore commercialista or ragioniere e perito commerciale, unless the employer runs them itself or through its own staff; small businesses may use their trade associations' services, and EU providers need no enrolment (Art. 1 L. 12/1979). A lawyer, dottore commercialista or ragioniere taking them on notifies the labour inspectorate. We only coordinate.
Our fee is quoted on request once the scope is known: the volume of transactions, staff on payroll, intra-group transactions and whether a transfer-pricing file is kept. The state's own charges are separate and listed on this page with their source: the books charge (Agenzia delle Entrate) and the deposit fees (Romagna chamber table, 2026).
When it must draw up consolidated accounts, controls an audited company, or exceeds one of EUR 4,000,000 assets, EUR 4,000,000 revenue or 20 employees for two consecutive years (Art. 2477 c.c.); Art. 9 D.Lgs. 47/2026 did not change this. The audit goes to a registered revisore legale or audit firm, a service we do not sell.
Under the Civil Code and the OIC standards (Organismo Italiano di Contabilità, the Italian standard setter). The IFRS decree reaches other companies only where they are not entitled to abbreviated accounts (Art. 2 D.Lgs. 38/2005). A reconciliation to the group's IFRS or US GAAP pack is a separate deliverable, planned with the parent's finance team.
Supplies to and from a parent not established in Italy go through the SDI as cross-border data: outgoing within the invoicing terms, incoming by the 15th day of the following month (Art. 1(3-bis) D.Lgs. 127/2015, text valid to 31 December 2026). Italian customers and suppliers exchange full SDI e-invoices (Agenzia delle Entrate).
Intra-group prices are set at arm's length (Art. 110(7) TUIR, as in force in 2026). On an adjustment, the 70% unfaithful-return penalty does not apply where the company holds the Masterfile and Documentazione Nazionale, has declared it and hands it over in an audit (Art. 1(6) D.Lgs. 471/1997, to 31 December 2026). Keeping the file is decided with you.
The annual accounts, presented within 120 days of year end (180 where the deed allows it for consolidated accounts or particular needs) and deposited within 30 days of approval; the Redditi SC and IRAP returns by the tenth month; the annual VAT return between 1 February and 30 April; the CU and the 770 where the company withholds tax.
On 2 November 2026, because 31 October 2026 is a Saturday; filing opened on 15 April 2026 (Agenzia delle Entrate). The statutory term is the last day of the tenth month after year end (Art. 2(2) D.P.R. 322/1998, as in force in 2026), and the IRAP return follows the same term.
Balance and first advance: by the end of the sixth month after year end (30 June, or 20 July 2026 for ISA taxpayers), or 30 days later at 0.40% (0.80% on the ISA date); for accounts lawfully approved after four months, by the end of the month after approval. Advance base 100%; second instalment by 30 November (Agenzia delle Entrate).
The annual charge on the corporate books: EUR 309.87, or EUR 516.46 where capital exceeds EUR 516,456.90, paid by 16 March on F24 code 7085 (Agenzia delle Entrate). Depositing the accounts costs EUR 65 stamp duty plus a EUR 60 secretarial fee plus the OIC contribution (Romagna chamber table, 2026); no total is printed, because the OIC contribution is not broken out.
A late or missed Register filing costs the directors EUR 103 to EUR 1,032, one third if made within 30 days (Art. 2630 c.c.). An omitted income or IRAP return costs 120% of the taxes due, at least EUR 250, and an unfaithful one 70% of the extra tax, at least EUR 150 (Art. 1 D.Lgs. 471/1997, text valid to 31 December 2026).
Books and invoices are kept for ten years from the last entry (Art. 2220 c.c.). The signed return and the transfer-pricing file are kept until the assessment term of Art. 43 D.P.R. 600/1973 lapses (Art. 3 D.P.R. 322/1998; Provvedimento 360494/2020). Electronic books carry a time stamp and a digital signature at least once a year (Art. 2215-bis c.c.).
Send us the company's year end, its owner and its activity; we reply with the calendar and who performs each act.