Holding Company in Italy: How PEX, Withholding Relief and the Shell-Company Test Work
"Holding company" names a function under Italian law, not a form. No article of the Codice civile creates a legal type by that name, so the vehicle is always an ordinary S.r.l. or S.p.A. What changes is the tax treatment once that company's object becomes taking and managing shareholdings: two 95% reliefs make the structure worth using, one statutory test can strip most of the benefit away, and one presumption can move the whole company's tax residence to Italy without anyone intending it. Every figure below carries its article and a link to the law.
Giulia Mancini, Head of Corporate Formation, Milan. Giulia started out preparing incorporation deeds in a Milan notary practice and has spent twelve years since on the same question founders keep asking: what does the statute actually require, and what is simply habit. More
Reviewed by Alessandro Ferri, Tax and Accounting Lead. Updated 11 September 2026.
What is a holding company under Italian law?
Three companies dominate a search for this term, and none of them is what the reader is actually looking for.
A holding is a function, not a company type
The Codice civile does not define "holding company" as a distinct legal type. Tax law recognises the function instead, by what the company does: a company qualifies as a holding where its "attività consiste in via esclusiva o prevalente nell'assunzione di partecipazioni", its activity consists exclusively or mainly in taking participations (Art. 87(5) TUIR). See Normattiva: TUIR, Art. 87. That single clause is the whole legal basis for everything that follows on this page.
The vehicle: an ordinary S.r.l. or S.p.A.
A founder incorporates an ordinary S.r.l. or S.p.A. and gives it the object of taking and managing participations. Nothing in company law requires a different vehicle, a different capital rule or a different filing. The S.r.l. answers for its obligations only out of its own assets (Art. 2462 c.c.); the S.p.A. carries a EUR 50,000 minimum capital (Art. 2327 c.c.). Full incorporation mechanics, capital and deadlines included, sit on Company in Italy: s.r.l. in italy and are not repeated here.
What this guide does not cover
Choosing between all six Italian forms belongs on our overview of the forms, which sets a holding-purpose company against every other structure available. Incorporation capital, notary deadlines and filing fees stay on /srl-italy/ and /spa-italy/. This page goes deep on the one dimension neither of those pages touches: what changes, in tax and compliance terms, once an ordinary company takes on a holding purpose.
Why do founders set up an Italian holding company?
Two reliefs, both set at 95%, do almost all of the work.
The first relief: 95% exemption on qualifying capital gains
Capital gains on a qualifying shareholding are 95% exempt from IRES under the participation exemption regime, commonly called PEX (Art. 87(1) TUIR). Only 5% of the gain is ever taxed. The conditions attached to this figure are covered in full below.
The second relief: 95% exclusion of dividends received
Dividends the holding receives from its subsidiaries are 95% excluded from taxable income (Art. 89(2) TUIR). Again, only the remaining 5% enters the tax base. The two reliefs share the same rate for a reason: both target the same problem, taxing the same corporate profit twice as it passes up through a group.
Why these two reliefs matter more for a holding than for a trading company
A trading company earns most of its income from selling something. A holding earns almost all of its income as capital gains and dividends. For an ordinary operating business, PEX and the dividend exclusion are incidental tax planning, useful when a shareholding happens to be sold or a subsidiary happens to pay a dividend. For a holding, they are not incidental at all: they are the mechanism that makes the structure economically viable in the first place. Strip either relief away and a two-tier group would be taxed twice on the same profit, once in the subsidiary and again on the way up.
How does participation exemption (PEX) work when the holding itself has no trading activity?
This is the question the current search results answer worst, and it is the single largest gap this page closes.
The four cumulative conditions
PEX requires four conditions to hold at once (Art. 87(1)(a)-(d) TUIR):
- Uninterrupted ownership from the first day of the twelfth month before the month of disposal.
- Classification as a financial fixed asset (immobilizzazioni finanziarie, the balance-sheet category for a long-term shareholding) in the first balance sheet closed during the holding period.
- The participated company is not resident in a low-tax jurisdiction identified under Art. 47-bis TUIR.
- The participated company carries on a genuine commercial activity under the Art. 55 TUIR definition.
See Normattiva: TUIR, Art. 87. Conditions 3 and 4 must hold without interruption from the first tax period of ownership, or, for a shareholding kept more than five years and sold outside the group, for the five tax periods before the sale (Art. 87(2) TUIR).
The look-through rule: Art. 87(5) tests the companies the holding owns, not the holding itself
Where the shareholding being sold is itself in a holding company, meaning a company whose activity consists exclusively or mainly in taking participations, conditions 3 and 4 are tested against the companies that holding indirectly owns, not against the holding's own accounts. The test is satisfied when those two conditions hold true for the investees representing the greater part of the selling holding's own net asset value. The statute reads: "i requisiti di cui alle lettere c) e d) del comma 1 si riferiscono alle società indirettamente partecipate e si verificano quando tali requisiti sussistono nei confronti delle partecipate che rappresentano la maggior parte del valore del patrimonio sociale della partecipante" (Art. 87(5) TUIR).
Why this is the rule that makes a two-tier structure work at all
A pure holding's own balance sheet is, by definition, mostly shareholdings rather than trading assets. Read condition 4 literally against the holding's own accounts and a founder could reasonably conclude that a pure holding never carries on a genuine commercial activity of its own, and so never qualifies for PEX on the sale of shares in it. Art. 87(5) is what closes that gap: it redirects the test down to the operating companies the holding actually controls. Without this provision, a two-tier group would arguably lose PEX at the parent level precisely because it is structured as a group.
Listed shares: condition 4 does not apply
Where the shares are listed and traded on a regulated market, the commercial-activity condition is disapplied altogether, and gains realised through a public offer are exempt regardless of it (Art. 87(4) TUIR).
How are dividends the holding receives from its subsidiaries taxed?
The second relief works on a simpler rule than PEX, with two exceptions worth knowing before the first distribution.
95% of dividends received are excluded from taxable income
Dividends distributed to a resident IRES subject, in any form and under any name, are excluded from taxable income to the extent of 95%: "esclusi dalla formazione del reddito della società o dell'ente ricevente per il 95 per cento del loro ammontare" (Art. 89(2) TUIR). See Normattiva: TUIR, Art. 89. Only the remaining 5% is taxed, the mirror image of the PEX figure above.
Dividends from a low-tax jurisdiction: the interpello route
Where the subsidiary paying the dividend is resident in a low-tax jurisdiction, the 95% exclusion survives only if the holding proves, through an interpello (a formal ruling request to the Agenzia delle Entrate), that the subsidiary carries on a genuine economic activity abroad. Without that proof, the dividend is taxed in full, with a matching foreign tax credit mechanism available where a controlling relationship exists (Art. 89(3) TUIR).
The IAS/IFRS trading-book exception
Where the recipient applies IAS/IFRS accounting standards and holds the shares for trading rather than as a long-term investment, the 95% exclusion does not apply at all, and the dividend is taxed on its full amount (Art. 89(2-bis) TUIR).
Two-tier diagram: an Italian holding sits above an operating subsidiary. Profits and dividends flowing up are 95% excluded from taxable income under Art. 89(2) TUIR. A sale of the subsidiary is a 95% exempt capital gain under PEX, Art. 87(1) TUIR. A note attached to the holding states that PEX conditions on commercial activity and residence are tested by look-through against the subsidiary, not against the holding itself, under Art. 87(5) TUIR.
Can a foreign parent reclaim the Italian withholding tax on dividends the holding pays out?
Yes, and the threshold that governs this has been corrected once already, quietly, in the law itself.
The threshold is 10% of the capital, held for at least one year
A qualifying EU or EEA parent holding at least 10% of the Italian holding's capital, directly and continuously for at least one year, can recover the Italian withholding tax charged on dividends paid out to it (Art. 27-bis(1)(d) D.P.R. 600/1973). See Normattiva: D.P.R. 600/1973, Art. 27-bis. Ten percent is the figure in force for profits distributed from 1 January 2009 onward, set by a later amending decree and recorded in the AGGIORNAMENTO note attached to the article, not in the article's printed body text itself (Art. 2 comma 2 D.Lgs. 49/2007). A reader who opens Article 27-bis and stops at the printed body will find a different, superseded figure there, one that was never the rate actually applied to a distribution under the rules in force. Ten percent is the number to rely on, full stop, and checking the AGGIORNAMENTO note attached to the article, not only its printed body, is what keeps a reader from getting this wrong.
The other three conditions: form, EU residence, tax subjection
Three further conditions apply alongside the 10%/1-year test (Art. 27-bis(1)(a)-(c) D.P.R. 600/1973): the parent must take a legal form listed in the annex to Directive 435/90/CEE; it must be tax resident in an EU member state without being treated, under a treaty with a non-EU country, as resident outside the EU; and it must be subject, in its state of residence, to one of the taxes the Directive lists, without benefiting from an unlimited optional or exempting regime.
Refund after payment, or no withholding at all at source
The qualifying parent has two routes. It can apply for a refund after the withholding has already been paid, supported by a residence certificate and its own declaration of the one-year holding period. Or it can ask the paying agent to withhold nothing at all at the point of payment, provided the supporting documents are obtained before the dividend is paid and kept until the assessment period expires (Art. 27-bis(2)-(3) D.P.R. 600/1973). The second route is faster in practice, since it avoids a separate refund claim entirely, but it depends on the paperwork being ready before, not after, the distribution.
Does that same relief apply to dividends the holding receives from a foreign subsidiary?
No, and this is the point generic guides get wrong most often.
No. Art. 27-bis relieves outbound withholding only
Art. 27-bis relieves Italy's own withholding tax on dividends an Italian holding pays out to a qualifying EU or EEA parent. It grants nothing at all on dividends the Italian holding receives from a subsidiary abroad. The direction only runs one way: out of Italy.
Inbound dividends are relieved on the Italian side by the ordinary 95% exclusion
Dividends flowing into the Italian holding from a foreign subsidiary are relieved by the ordinary Art. 89(2) exclusion already covered above, the same 95% mechanism that applies to dividends from an Italian subsidiary. Art. 27-bis plays no part in that relief at all.
Any withholding at the foreign source is that country's own law
Whatever withholding the foreign subsidiary's own country levies on the dividend before it reaches Italy is a matter of that country's domestic law and of the tax treaty between it and Italy, not of Italian law. That question sits outside the scope of this page.
Can the Art. 27-bis refund be denied to an artificial structure?
Yes, and the rule that denies it is not specific to holding companies at all.
The EU anti-abuse directive is implemented through Italy's general rule
The EU's anti-abuse directive on the parent-subsidiary regime is implemented in Italian law through the general abuse-of-law provision, not through a separate holding-specific test: "La direttiva (UE) 2015/121 del Consiglio, del 27 gennaio 2015, è attuata dall'ordinamento nazionale mediante l'applicazione dell'articolo 10-bis della legge 27 luglio 2000, n. 212" (Art. 27-bis(5) D.P.R. 600/1973). See Normattiva: L. 212/2000, Art. 10-bis.
What counts as abuse of law under Art. 10-bis
Abuse of law is "una o più operazioni prive di sostanza economica che, pur nel rispetto formale delle norme fiscali, realizzano essenzialmente vantaggi fiscali indebiti": one or more operations lacking economic substance that, while formally respecting tax rules, essentially realise undue tax advantages. Lack of economic substance means facts, acts and contracts "inidonei a produrre effetti significativi diversi dai vantaggi fiscali", unsuited to producing significant effects other than the tax advantage (Art. 10-bis(1)-(2) L. 212/2000).
The practical read: substance beats paperwork
A holding interposed purely to access the Art. 27-bis refund, with no economic function of its own beyond collecting a certificate and filing a claim, is exactly the fact pattern Art. 10-bis targets. Correct documentation does not cure a structure that has no substance behind it. The fix is genuine substance, covered in full further down this page.
Why is a passive holding structurally exposed to the "società di comodo" test?
This is the single most useful fact absent from the current search results, and it catches founders who did nothing wrong at all.
The test: actual revenue against a presumed minimum built from assets
A company is non operativa, "non-operative" or a shell company, if its total revenue, excluding extraordinary items, is lower than a presumed minimum computed by applying fixed percentages to the value of its own assets: "si considerano non operativi se l'ammontare complessivo dei ricavi, degli incrementi delle rimanenze e dei proventi, esclusi quelli straordinari, risultanti dal conto economico, ove prescritto, è inferiore alla somma degli importi che risultano applicando le seguenti percentuali" (Art. 30(1) L. 724/1994). See Normattiva: L. 724/1994, Art. 30.
The percentages by asset class
The presumed minimum revenue is built from four rates: 1% of shareholdings and similar financial assets, 3% of real estate (with reduced sub-rates for certain categories), 6% of the specific asset class referred to in Art. 8-bis(1)(a) D.P.R. 633/1972, and 15% of other fixed assets. The full set of figures, alongside the parallel minimum-income rates, stands in the data table below.
Why a holding's own asset mix leaves it exposed despite the lowest rate
A holding's assets sit almost entirely in the 1% bracket, the lowest rate the test applies. That sounds favourable, and in isolation it is. The trap is on the other side of the comparison: a passive holding's own ordinary revenue is frequently minimal, sometimes close to nil, because its economic return arrives as dividends and capital gains, not as ricavi, ordinary trading revenue, which is the only figure this test actually measures. A holding with several million euro of shareholdings and no trading revenue of its own can fail the test outright, not because anything went wrong, but because that is exactly what a purely passive holding structurally looks like on this specific test.
What happens if the holding fails the test, and which holdings are excluded?
Two consequences follow, and one exclusion changes the picture completely for a specific kind of holding.
The minimum-income presumption
A company found non-operative is presumed, for IRES purposes, to have earned taxable income not lower than a second set of percentages applied to the same assets: 0.75% of shareholdings and financial assets, 2.38% of real estate, 4.75% of the Art. 8-bis assets, and 12% of other fixed assets (Art. 30(3) L. 724/1994). The company pays tax on this presumed figure even where its actual result was lower, or a loss.
The 10.5-point IRES surcharge
On top of the presumed income, a società di comodo pays an additional 10.5 percentage points on the ordinary IRES rate (Art. 2, commi 36-quinquies to 36-novies D.L. 138/2011). See Agenzia delle Entrate: scadenzario, società di comodo. Combined with the standard 24% rate, that is a materially higher tax bill on income the company may never actually have earned.
The one exclusion that matters: controlling a listed company
A company that controls another company or entity whose securities trade on an Italian or foreign regulated market is excluded from the whole regime, together with the listed company itself and its own subsidiaries, even indirect ones (Art. 30(1)(4) L. 724/1994). For a holding sitting above a listed operating company, this single exclusion removes the entire exposure described above.
Actual revenue is compared against a presumed minimum revenue computed at 1% of shareholdings under Art. 30(1) L. 724/1994; real estate, Art. 8-bis assets and other fixed assets carry their own higher rates of 3%, 6% and 15%. Falling short means a presumed minimum income plus a 10.5-point IRES surcharge under Art. 30(3) L. 724/1994 and D.L. 138/2011. A holding controlling a company listed on a regulated market is excluded entirely, under Art. 30(1)(4) L. 724/1994.
Other exclusions exist, but rarely help a small holding vehicle
The statute lists several other exclusions: the company's first tax period, insolvency or liquidation proceedings, 50 or more shareholders, 10 or more employees in each of the two preceding years, a value of production exceeding total balance-sheet assets, at least 20% public ownership, and a now largely superseded consistency test. None of these realistically applies to a small, purpose-built holding vehicle with one or two shareholders and no employees of its own. They exist in the statute; they are not live options for the audience this page is written for.
When is a foreign holding company deemed Italian tax resident anyway?
Placing the holding outside Italy solves nothing if the holding is actually run from Italy.
The three residence tests, any one is enough
A company is Italian tax resident if, for the greater part of the tax period, it has in Italy its registered office, its place of effective management (sede di direzione effettiva), or its ordinary management on a principal basis. The three tests are alternative: satisfying just one is enough to make the company Italian-resident (Art. 73(3) TUIR). See Normattiva: TUIR, Art. 73.
The reverse presumption for a foreign holding controlling an Italian company
A specific presumption targets exactly the manoeuvre a founder might be tempted to try. Unless proved otherwise, a foreign company holding a controlling participation in an Italian IRES subject is itself deemed Italian tax resident if it is controlled, even indirectly, by persons resident in Italy, or if its board is composed predominantly of Italian-resident directors: "si considerano altresì residenti nel territorio dello Stato le società ed enti che detengono partecipazioni di controllo … sono amministrati da un consiglio di amministrazione, o altro organo equivalente di gestione, composto in prevalenza di consiglieri residenti nel territorio dello Stato" (Art. 73(5-bis) TUIR). Putting the holding company on paper in a lower-tax EU state while continuing to run it from Milan does not move its tax residence anywhere. This reverse presumption, called esterovestizione, is built specifically to catch that pattern, independently of the Art. 10-bis anti-abuse rule covered above.
When control is tested
Control, for the purposes of this presumption, is tested at the closing date of the foreign company's own financial year (Art. 73(5-ter) TUIR).
Can two Italian companies under one holding file a single tax return?
Yes, through an election most guides on this topic never mention at all.
Who may elect, and the >50% control threshold
A controlling company and each controlled company among the IRES subjects listed in Art. 73(1)(a)-(b) TUIR, provided the Art. 2359(1)(1) c.c. control relationship exists between them and the Art. 120 requirements are met, may jointly elect group taxation, known as consolidato fiscale nazionale (Art. 117(1) TUIR). See Normattiva: TUIR, Art. 117. The control threshold is direct or indirect participation exceeding 50% of the controlled company's capital (Art. 120(1)(a) TUIR). See Normattiva: TUIR, Art. 120.
How long the election runs
Once the control requirement continues to be met, the election runs for three corporate years and is irrevocable during that period. At the end of the three years it is tacitly renewed for a further three years, unless revoked in the same form and within the same time limits as the original election (Art. 117(3) TUIR). For a holding sitting above two or more Italian operating subsidiaries, the practical effect is a single group IRES position instead of several separate returns, computed and filed together.
What overall tax rate does an Italian holding pay?
The rate itself holds no surprise; the surcharge covered above is the only variable.
IRES 24%, IRAP 3.9%, the same as any other Italian company
An Italian holding pays IRES at the standard rate of 24% and IRAP at the standard rate of 3.9%, identical to any other Italian company. See Agenzia delle Entrate: IRES. The higher IRAP sector rates apply only to banks, financial intermediaries and insurers, categories a plain equity holding does not fall into absent a separate authorisation as a financial intermediary. The calculation method and the full compliance calendar sit on the tax overview and are not repeated here.
The società di comodo surcharge is the only variable
The one way this rate actually changes for a holding specifically is the 10.5-point surcharge covered above, and it is avoidable: either by passing the revenue test on the holding's own numbers, or by qualifying for the listed-subsidiary exclusion where it applies.
| Indicator | Value | Article |
|---|---|---|
| PEX exemption on qualifying capital gains | 95% | Art. 87(1) TUIR |
| PEX minimum holding period | 12 months (from the 1st day of the 12th month before disposal) | Art. 87(1)(a) TUIR |
| Dividend exclusion from taxable income | 95% | Art. 89(2) TUIR |
| EU parent-subsidiary refund: capital threshold | 10%, held directly | Art. 27-bis(1)(d) D.P.R. 600/1973; Art. 2 comma 2 D.Lgs. 49/2007 |
| EU parent-subsidiary refund: holding period | 1 year, uninterrupted | Art. 27-bis(1)(d) D.P.R. 600/1973 |
| Società di comodo revenue test: shareholdings/financial assets | 1% of value | Art. 30(1) L. 724/1994 |
| Società di comodo revenue test: real estate | 3% (2.5% / 2% / 0.5% sub-rates) | Art. 30(1) L. 724/1994 |
| Società di comodo revenue test: Art. 8-bis assets | 6% of value | Art. 30(1) L. 724/1994 |
| Società di comodo revenue test: other fixed assets | 15% of value | Art. 30(1) L. 724/1994 |
| Società di comodo minimum-income test: shareholdings/financial assets | 0.75% of value | Art. 30(3) L. 724/1994 |
| Società di comodo minimum-income test: real estate | 2.38% (2% / 1.5% / 0.45% sub-rates) | Art. 30(3) L. 724/1994 |
| Società di comodo minimum-income test: Art. 8-bis assets | 4.75% of value | Art. 30(3) L. 724/1994 |
| Società di comodo minimum-income test: other fixed assets | 12% of value | Art. 30(3) L. 724/1994 |
| IRES surcharge for a società di comodo | +10.5 percentage points | Art. 2, commi 36-quinquies-36-novies D.L. 138/2011 |
| IRES, standard rate | 24% | Agenzia delle Entrate |
| IRAP, standard rate | 3.9% | Art. 16(1) D.Lgs. 446/1997 |
| Consolidato fiscale: control threshold | >50% of capital | Art. 120(1)(a) TUIR |
| Consolidato fiscale: election duration | 3 years, irrevocable, tacitly renewed | Art. 117(3) TUIR |
| Minimum S.r.l. capital, for contrast | EUR 10,000 | Art. 2463(2)(4) c.c., full facts on /srl-italy/ |
| Minimum S.p.A. capital, for contrast | EUR 50,000 | Art. 2327 c.c., full facts on /spa-italy/ |
This table states statutory rates, thresholds and government figures. It carries no service price and no fee of ours: our own pricing is on request.
Holding company vs. an ordinary S.r.l. or S.p.A.: what's actually different?
Nothing changes at the company-law level. Three things change everywhere else.
Company-law facts belong to /srl-italy/ and /spa-italy/, not here
Incorporation, share capital and governance for a holding-purpose company are identical, article for article, to an ordinary S.r.l. or S.p.A. Nothing about choosing a holding purpose changes the deed, the capital requirement or the filing route. Those facts live on the two dedicated pages and are not restated here.
The three things unique to a holding: PEX look-through, comodo exposure, substance
What actually changes, once a company's object becomes taking and managing participations, comes down to three consequences. First, the Art. 87(5) look-through rule, which is what lets PEX apply at all to a company with no trading activity of its own. Second, the structural exposure to the società di comodo test, built into a holding's asset mix rather than caused by anything the founder did wrong. Third, the substance requirement: a foreign holding actually run from Italy gains nothing from being incorporated abroad, and an artificial structure can lose the Art. 27-bis refund regardless of paperwork.
When a lighter structure might fit better instead
Not every founder asking about a holding actually needs one. A founder with a single operating company and no plan to hold shares in anything else usually needs set up a company in Italy, not a two-tier structure. A founder building one company from scratch, rather than structuring a group, may find innovative startup in Italy status a lighter route, with benefits that a holding-purpose vehicle does not carry.
Frequently asked questions
Is there a special legal form for a holding company in Italy?
No. An ordinary S.r.l. or S.p.A. is used; tax law defines a holding only by its activity, taking and managing participations, under Art. 87(5) TUIR.
Why set up an Italian holding company?
Mainly for two 95% reliefs: the exemption on capital gains from qualifying shareholdings (PEX, Art. 87 TUIR) and the exclusion of dividends received from subsidiaries (Art. 89(2) TUIR).
Does PEX still work if the holding itself has no trading activity of its own?
Yes. Art. 87(5) TUIR tests the commercial-activity and residence conditions against the companies the holding indirectly owns, not against the holding's own accounts. This is what makes a two-tier structure work for PEX at all.
How much of the dividends an Italian holding receives from its subsidiaries is taxed?
Only 5%. The other 95% is excluded from taxable income under Art. 89(2) TUIR, unless the recipient holds the shares for IAS/IFRS trading purposes, in which case the full amount is taxed.
Can a foreign parent reclaim the Italian withholding tax on dividends paid by its Italian holding?
Yes, under Art. 27-bis D.P.R. 600/1973, if it holds at least 10% of the capital continuously for at least one year and meets the form, residence and tax-subjection conditions.
Does that same rule help with dividends the Italian holding receives from a foreign subsidiary?
No. Art. 27-bis relieves only Italy's own withholding on dividends flowing out of Italy; inbound dividends are relieved on the Italian side by the ordinary 95% exclusion under Art. 89(2) TUIR.
Can the tax authorities deny the Art. 27-bis refund to an artificial structure?
Yes. The EU anti-abuse rule is implemented through Italy's general abuse-of-law provision (Art. 10-bis L. 212/2000), which targets arrangements without economic substance whose essential purpose is a tax advantage.
Why is a passive holding at risk of being treated as a "società di comodo"?
The statutory test compares actual revenue against a presumed minimum built from the company's own assets; a holding with mostly shareholdings and little revenue of its own can fail it, triggering a presumed minimum income and a 10.5-point IRES surcharge.
Is a holding automatically excluded from the società di comodo rules?
No, but a holding that controls a company listed on a regulated market is expressly excluded from the whole regime, together with the listed company and its own subsidiaries.
Can a foreign holding company own an Italian company without becoming Italian tax resident itself?
Only if it is not, in substance, controlled by Italian residents or run by a board composed mainly of Italian-resident directors; otherwise Art. 73(5-bis) TUIR deems it Italian-resident regardless of where it is incorporated.
Can two Italian companies under one holding file a single tax return?
Yes, through consolidato fiscale nazionale, if the holding controls more than 50% of each company's capital under Art. 120(1)(a) TUIR; the election runs three years and renews tacitly.
What overall tax rate does an Italian holding company pay?
The standard IRES rate of 24% and IRAP of 3.9%, the same as any other Italian company, plus the 10.5-point società di comodo surcharge only if the revenue test is failed and no exclusion applies.