Shell companies in the 2026 Italian tax return: operating test, exclusions and disapplication

The rules on non-operating companies require actual revenues to be compared with deemed revenues, obtained by applying statutory coefficients to the value of certain assets: shareholdings, real estate and other fixed assets. Failing the test triggers a minimum deemed income, restrictions on the use of the VAT credit and an increased corporate income tax rate.

Before accepting the minimum deemed income, however, it is worth checking the grounds for exclusion and automatic disapplication, as well as the option of relying on objective circumstances that prevented revenues from being earned. The position must be documented in the return itself: during an audit the burden of explaining the anomaly falls on the taxpayer, and a case reconstructed after the fact is far weaker.

Summary note by the CommercialistiAvvocati network, based on specialised legal and practice sources. The text does not reproduce original contributions and does not constitute professional advice.