The reduced IRES rate, and the other tax on the SRL: IRAP

Marco's SRL earned 300,000 € of taxable income in 2025. At the ordinary rate that means 72,000 € of IRES; at the reduced rate, 60,000 €. The 12,000 € difference is real, but it belongs only to a company that set aside its 2024 profits, invested them, hired and avoided the wage guarantee fund. Claiming it without all four is the costliest line of the return.

One tax period, not a new rate

The reduced rate comes from the 2025 Budget Law, Law 207/2024, article 1, paragraphs 436 to 444. Its declared aim is to encourage investment and employment. It lowers the IRES rate from 24 to 20 per cent, but only for a single tax period and only when every condition is met.

The period is described precisely: the tax period following the one in progress on 31 December 2024. For a company whose financial year matches the calendar year, that is 2025. The return for 2025 is filed in 2026, which is why a 2026 course deals with it.

A company with a different financial year must count carefully. The reference is the period in progress on 31 December 2024, whatever its start date. The reduced rate applies to the next one, and to that one only. No earlier or later period benefits, even if the conditions happen to be met.

The practical detail is not left to the law alone. The Agenzia states that the implementing rules are in the ministerial decree of 8 August 2025, and that paying IRES at the reduced rate requires the specific F24 tax codes created by resolution 57 of 17 October 2025. The ordinary codes do not serve.

The conditions, one by one

The Agenzia lists the conditions in a single long sentence. Read slowly, it contains five separate tests. Failing any of them brings the rate back to 24 per cent for the whole taxable income: there is no partial reduction for a company that meets four tests out of five.

The first test concerns the reserve. At least 80 per cent of the 2024 profits must be allocated to a dedicated reserve. The base is the profit of 2024, not of 2025: the reduced rate rewards a company for keeping last year's earnings inside the business rather than distributing them.

The second test concerns investment. At least 30 per cent of the profits placed in that reserve must be invested in new capital goods qualifying under the Transizione 4.0 or Transizione 5.0 schemes, used in production sites located in Italy. Second-hand goods do not count, nor do goods used abroad.

The investment has two floors besides that percentage. It may not be lower than 24 per cent of the 2023 profits, and in any case not lower than 20,000 €. The figure of 24 per cent here is a coincidence with the ordinary rate; the two numbers have nothing to do with each other.

The third test concerns the workforce as a whole. In 2025 the number of annual work units must not fall below the average of the three previous years. A company that shed staff during the year fails here even if it hired elsewhere, because the comparison is with a three-year average.

The fourth test concerns new hiring. The company must take on new permanent employees so as to raise employment by at least 1 per cent compared with the tax period in progress on 31 December 2024. Fixed-term contracts do not help; the text speaks of lavoratori dipendenti a tempo indeterminato.

The fifth test is negative. The company must not have used the cassa integrazione guadagni, the wage guarantee fund, in the period in progress on 31 December 2024 or in the next one. The Agenzia notes an exception for temporary events not attributable to the business or its staff, including seasonal bad weather.

• Reserve: at least 80 per cent of 2024 profits allocated to a dedicated reserve
• Investment: at least the highest of the three floors, in new 4.0 or 5.0 goods used in Italy
• Workforce: annual work units in 2025 not below the average of the three previous years
• Hiring: permanent employment up by at least 1 per cent
• Wage guarantee fund: not used in 2024 or 2025, save the stated exceptions

The example shows who the absolute floor hurts. For a small company the percentages produce modest amounts, and the fixed floor overtakes them. An SRL with small profits must therefore invest a far larger share of them than the 30 per cent headline suggests, or forgo the reduced rate.

ActioFin's IRES calculator tests all five conditions. It computes the minimum reserve and the minimum investment from the figures you enter, and it names the condition that fails. It relies on what you declare: it cannot check the evidence, and the implementing decree is not modelled in it.

Evidence is therefore the owner's business. Keep the members' resolution allocating the 2024 profits to the reserve, the invoices and certifications of the qualifying goods, and the employment records that support the headcount comparisons. A reduced rate claimed in the return must be provable line by line if the Agenzia asks.

IRAP: the second tax on the SRL

An SRL pays a second tax on its activity, IRAP, the imposta regionale sulle attività produttive. According to the Ministry of Economy and Finance, its rules are in articles 1 to 45 of Legislative Decree 446 of 15 December 1997. It is distinct from IRES, with its own base, return and rates.

The Ministry names as IRAP taxpayers those who carry on a business or self-employed activity, individually or in association, private non-commercial bodies and public administrations. Several groups are excluded, and two of the exclusions matter for anyone comparing an SRL with working in their own name.

Individuals under the forfettario flat-rate regime are outside IRAP. Since the tax period in progress on 1 January 2022, IRAP is also not due from individuals carrying on commercial activities with business income, nor from individuals exercising arts and professions. An SRL enjoys neither exclusion: it remains subject to IRAP.

Labour costs deserve a word. Since the tax period in progress on 31 December 2015, the full cost of employees on permanent contracts can be deducted from the IRAP base. The deduction was later extended, within specific limits, to certain seasonal workers. This is why IRAP weighs differently on two SRLs with the same profit.

IRAP is a regional tax in name and in use. The Ministry calls it a tributo proprio derivato: established and governed by State law, with its revenue attributed to the regions, which contributes to financing the national health service. Regions may vary the rates by law, within limits set by the State.

The procedure mirrors that of income taxes. Each period, the taxpayer files the IRAP return prepared by the Agenzia delle Entrate. The tax is self-assessed and paid with the F24: an advance split into two instalments during the year, and a balance paid in the following year after the return.

Why no IRAP rate appears here

Every other tax in this course comes with its rate. IRAP does not, and the gap is deliberate. On 24 September 2026, the consolidated text of the law on the Gazzetta Ufficiale and the Ministry's own page did not show the same ordinary rate. Two official sources that disagree cannot both be taught.

Choosing one of them would be a guess dressed as a fact. The contradiction is recorded and awaits an expert review that reads both texts and settles which one applies. Until then, the course tells you where the rates are published and why they vary, not what they are.

Even a settled ordinary rate would not be the rate of your company. The Ministry's page shows several rates by type of taxpayer, increases for certain activities from the period following 2025, regional variations and automatic increases in regions under health deficit recovery plans. The rate actually due depends on the region and the sector.

The regions publish the data needed to compute the tax on the federalismo fiscale portal, for publication on the Ministry's website, by 31 March of the year concerned. That publication, together with your accountant, is the reliable route to your company's IRAP rate. This course will not shortcut it.