Investing in Italy: Corporate Tax Incentives and Reliefs — 2026 Overview

Companies and sole proprietors planning to invest in Italy can benefit from several corporate tax incentives. The corporate income tax rate (IRES) stands at 24% (plus regional IRAP, typically 3.9%). In addition, a research and development tax credit, the Patent Box regime and an advance tax ruling procedure for new investments are available.

1. Research and development tax credit (Credito d’imposta R&S)

Objective: to encourage investment in basic research, industrial research and experimental development.

How the regime works

• For 2026, a tax credit of 10% of eligible research and development expenditure applies, capped at €5 million per year and per beneficiary.
• The rate is guaranteed by law until 2031.
• For design and aesthetic innovation activities, a 10% rate also applies for 2026, capped at €2 million per year.
• The credit can only be used by way of offsetting (form F24), spread over three equal annual instalments starting from the year following the one in which the costs were incurred.
• Certified (sworn) technical documentation and an audit certification of the accounts are mandatory conditions for claiming the credit.

Who can benefit: all companies resident in Italy, regardless of legal form, sector or size, including Italian permanent establishments of non-resident companies.

Combining the credit with the Patent Box is generally possible, as long as the cumulative benefit does not exceed the costs actually incurred.

2. Patent Box

Objective: to encourage investment in the development and exploitation of intangible assets.

Eligible intangible assets: copyright-protected software, patents, designs and models, provided they are used in the business activity.

How the regime works

• A 110% super-deduction applies to qualifying R&D costs connected with the eligible intangible assets.
• Example: €100 of costs results in a total tax deduction of €210 (€100 of actual costs plus the 110% extra deduction).
• The resulting tax benefit amounts to roughly 30.69% of the qualifying costs (calculated on IRES at 24% plus IRAP at 3.9%).
• The benefit is calculated and claimed directly in the tax return (“self-assessment”), with no prior ruling procedure.
• Where proper technical documentation is in place, a “penalty protection” mechanism shields the taxpayer from sanctions in the event of a later challenge.
• R&D costs incurred in up to 8 tax periods preceding the grant or registration of the IP right can retroactively qualify for the super-deduction.

Who can benefit: companies, sole proprietors and other entities earning business income that carry out R&D activities — including through third parties — as well as Italian permanent establishments of non-resident companies from countries with an effective exchange of tax information with Italy.

The quality of the supporting technical documentation is decisive, as it determines whether penalty protection applies in the event of a dispute.

3. Advance tax ruling for new investments (Interpello sui nuovi investimenti)

Objective: a binding opinion from the Agenzia delle Entrate (Italian Revenue Agency) on the tax treatment of a significant investment project in Italy and its implementation.

Requirements

• The investment project must be carried out in Italy.
• It must have significant and lasting employment effects.
• The investment value must be at least €15 million.

Who may file a request

• Italian and foreign corporations and other resident entities, including those controlled by non-resident entities
• non-resident companies and entities of any kind, whether or not they maintain a permanent establishment in Italy
• sole proprietors and non-commercial entities, limited to any business activities they carry out
• individuals and non-commercial entities planning an investment in an Italian target company (asset deal or share deal)
• banking foundations and collective investment undertakings (including those not resident in Italy, provided they are subject to supervision in their home state)
• corporate groups and business combinations

Effect of the reply: the reply is binding on the Agenzia delle Entrate with regard to the specific investment project as described, as long as the legal and factual circumstances remain unchanged. Administrative acts that contradict the reply are null and void. Any audit activity concerning the investors must be coordinated with the responding department.

Procedure: the request can be filed in person, by registered mail with return receipt, or by certified email (PEC) with the competent central directorate of the Agenzia delle Entrate in Rome. The statutory response period is 120 days.

Summary

Legal references

• R&D tax credit: Art. 1, paras. 198–209, Law No. 160/2019, as last amended by Law No. 199/2025 (2026 Budget Law); implementing decree of the MIMIT of 26 May 2020 (mimit.gov.it)
• Patent Box regime: Art. 6, Decree-Law No. 146/2021 (converted into Law No. 215/2021), as amended by Law No. 234/2021 (2022 Budget Law); “Patent box – I benefici” page of the Agenzia delle Entrate (agenziaentrate.gov.it)
• Advance tax ruling / Interpello sui nuovi investimenti: Art. 2, Legislative Decree No. 147/2015, as amended by Art. 8, paras. 6–7, Law No. 130/2022; “Interpello sui nuovi investimenti” page of the Agenzia delle Entrate (agenziaentrate.gov.it)

Law as of July 2026. Before application to a specific case, the current version of the legislation cited should be checked, as the rates set annually (R&D tax credit, design tax credit) in particular may be subject to change.

Which of these instruments may apply to a specific investment project in Italy should be assessed on a case-by-case basis with a qualified tax advisor.