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ItalianoReduced IRES at 20%: Meeting Initial Conditions Is Not Enough!
The reduced 20% IRES rate is not granted just by meeting the initial conditions; compliance with two additional requirements is necessary: Failure to comply with these conditions results in the loss of the tax benefit, making careful planning and monitoring of investments essential to avoid penalties.
IRES Premium: Meeting the Ex Ante Conditions is Essential!
Law No. 207/2024 has introduced an important tax benefit, with a reduced rate of 20% for 2025. However, in order to benefit from this advantage, it is crucial to meet certain pre-established conditions (ex ante conditions). What are the main requirements? Businesses must meet five key conditions: By meeting these conditions, companies can benefit from […]
20% Rewarded IRES: A Not-to-Be-Missed Opportunity for 2025!
The year 2025 brings a valuable opportunity for capital companies and commercial entities operating in Italy: a reduced 20% IRES rate instead of the usual 24%. However, to qualify for this tax benefit, businesses must meet five key conditions. Among the most important: ✅ Allocation of 80% of the 2024 profit to a dedicated reserve.✅ […]
International taxation and tax credit: the clarification of the Court of Cassation
The Italian Supreme Court has recently reaffirmed a key tax principle: the foreign income tax credit is granted only if such income is actually subject to taxation in Italy. This means that if an income is exempt from taxation under an international double taxation treaty, the taxpayer cannot claim the tax credit. The clarification provided […]
Horizon Consulting Italia alongside International Education Camp
Horizon Consulting Italia has recently and successfully supported the establishment of the Italian branch of International Education Camp, a dynamic and innovative organization that promotes language learning through immersive and educational experiences. We had the pleasure of collaborating with the founders, Tom Johnson and Joel Rosenblatt, two professionals with a clear and ambitious vision: making […]
The Principle of Effective Taxation Abroad
The Court of Cassation has reaffirmed a fundamental principle regarding tax credits: they can only be granted for foreign taxes that have been effectively due and paid. This means that tax credits cannot be claimed for potential or theoretical taxes but only for those actually collected by the foreign state. The decision aims to ensure […]
EU Omnibus Package: Streamlining Sustainability
Last week, the European Commission introduced a package of measures aimed at initiating a review and simplification of regulations to reduce administrative burdens while ensuring the implementation of the Green Deal does not hinder economic growth. With a focus on reducing reporting requirements, the so-called Omnibus package is assessing the following measures: Simplification of Reporting […]
Limits on the Foreign Tax Credit
The foreign tax credit cannot exceed the amount of Italian tax theoretically due on the same income. In other words, the maximum recognized amount is equal to the portion of Italian tax corresponding to the foreign income. If the tax paid abroad exceeds this limit, the excess cannot be recovered, unless specific provisions allow for […]
Foreign Taxes and Tax Credit: Regulations and Application Limits
The foreign tax credit is granted only under specific conditions. According to the Court of Cassation, the benefit is allowed only if the tax has actually been paid abroad and if the income on which it was applied is taxable in Italy. Another limitation comes from double taxation treaties. If these agreements provide for the […]
Double Taxation on Dividends and the Tax Credit
Dividends received by an individual may be subject to double taxation: The Court of Cassation has clarified that the foreign tax credit is granted only if the foreign tax is levied as an income tax and not as a different type of levy.
