Module 221 min2259 wordsFree — no account
The reduced IRES rate, and the other tax on the SRL: IRAP
The module’s worked examples, then cases to attempt before revealing their solution · 3 sections · 479 words · 5 min
Worked example
Why the 20,000 € floor bites on small companies
An SRL made 40,000 € of profit in 2024 and 30,000 € in 2023. It places all 40,000 € in the reserve. Thirty per cent of the reserve is 12,000 €; twenty-four per cent of the 2023 profits is 7,200 €. Both are below 20,000 €, so the minimum investment is 20,000 €, half of the entire reserve.
Practical case
Marco's SRL and the reduced rate
Marco's SRL keeps calendar-year accounts. Its 2024 profit was 250,000 € and it placed 210,000 € in a dedicated reserve. Its 2023 profit was 180,000 €. In 2025 it invested 70,000 € in new Transizione 4.0 machines installed in its Italian plant, raised permanent employment by 1.5 per cent, kept its annual work units above the three-year average and never used the wage guarantee fund. Its 2025 taxable income is 300,000 €. Which rate applies, and how much IRES is due?
Hint: Test each condition in turn. For the investment, compute all three floors and keep the highest.
Show the solution
Reserve: 80 per cent of 250,000 € is 200,000 €; the company reserved 210,000 €, so the test is met. Investment: 30 per cent of the 210,000 € reserved is 63,000 €; 24 per cent of the 2023 profit of 180,000 € is 43,200 €; the absolute floor is 20,000 €. The highest is 63,000 €, and 70,000 € were invested, so the test is met. Employment rose by 1.5 per cent, above the 1 per cent required; work units did not fall; the fund was not used. All conditions hold for 2025, so the rate is 20 per cent: 300,000 × 20 % = 60,000 €. At the ordinary rate the tax would have been 72,000 €.
Answer: Reduced rate applies: 60,000 € of IRES, a saving of 12,000 €
Practical case
The small SRL that invested too little
A small SRL with calendar-year accounts made 40,000 € of profit in 2024 and 30,000 € in 2023. It placed the whole 2024 profit in the dedicated reserve and invested 15,000 € in new qualifying goods in 2025. It met the employment conditions and did not use the wage guarantee fund. Its 2025 taxable income is 50,000 €. Does it obtain the reduced rate, and what IRES does it owe?
Show the solution
Reserve: 80 per cent of 40,000 € is 32,000 €, and the company reserved 40,000 €, so this test is met. Investment: 30 per cent of the 40,000 € reserved is 12,000 €, 24 per cent of the 2023 profit of 30,000 € is 7,200 €, and the absolute floor is 20,000 €. The highest floor is 20,000 €. The company invested only 15,000 €, so the investment condition fails. One failed condition is enough: the ordinary rate applies to the whole taxable income, 50,000 × 24 % = 12,000 €.
Answer: No reduced rate: 12,000 € of IRES at the ordinary rate
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