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The 2025 Budget Law (L. 207/2024) introduced, applicable only to the tax period following the one in progress on 31.12.2024, a significant tax incentive: the application of a reduced IRES rate of 20% (as opposed to 24%) for corporations that meet specific requirements.

With Ruling No. 81/2025, the Italian Tax Authorities have addressed a case of international taxation regarding the payment of a Long-Term Cash Bonus to an employee who had returned to Italy. The Authorities clarified that taxation must occur in the country where the work activity was effectively carried out during the vesting period, regardless of the beneficiary’s tax residence at the time of payment.