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One of the initiatives taken by the 2025 Budget Law has been to modify the standard 24% (Imposta sul Reddito delle Società or IRES) for the year 2025, making it a 20% corporate income tax if certain conditions are met.
The requirements for obtaining this special rate include:
a) reserve at least 80% of the 2024 profits for a minimum of two years in a special capital reserve and invest at least 30% of these retained earnings in new capital goods "Transizione 4.0" or "Transizione 5.0", intended for production facilities located in Italy; b) in 2025 the number of work units per year must not decrease compared to the average of the previous three years and new employees must be hired with permanent contracts to ensure an employment increase of at least 1% compared with the current tax period on 31st December 2024; c) the company must not have used the redundancy fund (Cassa Integrazione) in the current financial year as of December 31st 2024, or the following period.
The 2025 budget has extended the increase in the cost of personnel admitted to deduction for three further years, making it applicable for the tax periods 2025, 2026 and 2027. This benefit encourages new recruitment and promotes employment, with particular attention to disadvantaged categories of workers. The facility is dedicated to Enterprises (companies, partnerships, sole proprietors); Businesses and professions, including associated businesses; Non-commercial entities, limited to the recruitment of personnel employed in commercial activities. The employment increase is considered achieved if, at the end of the period of preferential treatment (fiscal year 2024), the number of permanent employees is higher than in the previous year.
The 2025 Budget introduces a reverse charge for the performance of companies operating in the transport, freight handling and logistics services sectors for contracts, subcontracting, contracts to consortia or other negotiation relationships characterised by a predominant use of labor and capital goods provided by the customer. Generally, the reverse charge mechanism implies that the obligations relating to the application of VAT must be fulfilled by the taxable person who takes over or commits the transaction in place of the transferor or the lender. The new provision provides that, for services rendered to undertakings engaged in freight transport and handling activities and logistics services, the supplier and the customer may choose to have the VAT on the services rendered paid by the customer in the name and on behalf of the supplier, who is jointly liable for the tax due. In such cases, the invoice is issued by the provider and the tax is paid by the client without possibility of compensation, referring to the month following the date of issue of the invoice by the provider. It is also provided that if the tax is not due, the right to reimbursement belongs to the person who ordered the service on condition that he proves the actual payment of the tax.
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