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IRAP in Italy – Who Still Pays It in 2026?

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IRAP – Imposta Regionale sulle Attività Produttive

IRAP  is a regional Italian tax originally introduced in 1997. For many years it was one of the more controversial and heavily litigated areas of the Italian tax system, particularly for self-employed professionals and small businesses.

Today, however, IRAP is far less important for many individuals because significant categories of taxpayers have been removed from the tax altogether.

This article provides a short practical overview of how IRAP works in 2026 and, more importantly, who still needs to worry about it.

What is IRAP?

IRAP is a regional tax applied to productive activities carried out in Italy.

Unlike ordinary income tax, IRAP is not based simply on net taxable income. Historically it was calculated using a separate tax base intended to reflect the gross margin or “value added” generated by a business or professional activity.

The rules can become technically complex, particularly for companies and larger businesses.

Who Still Pays IRAP in 2026?

IRAP generally still applies to:

  • Italian companies (SRL, SPA etc.)
  • Partnerships
  • Commercial entities
  • Banks and insurance companies
  • Certain permanent establishments in Italy

In practice, incorporated businesses will often still need to consider IRAP as part of their annual Italian tax compliance.

Who No Longer Pays IRAP?

One of the most important reforms in recent years was the removal of IRAP for many individuals operating business or professional activities personally.

In general terms, IRAP no longer applies to:

  • Individual professionals
  • Freelancers
  • Sole proprietors
  • Individual entrepreneurs

This exemption has significantly reduced the practical relevance of IRAP for many smaller activities in Italy.

Typical IRAP Rates

Standard Rates

The standard IRAP rate is generally around 3.9%, although rates can vary depending on:

  • the region
  • the nature of the activity
  • the type of taxpayer

Certain sectors, such as banks and insurance companies, may be subject to higher rates.

Regional Variations

The following table provides a general indication of the ordinary regional IRAP rates often encountered in practice. Exact rates should always be verified for the relevant tax year.

Italian Region Typical Ordinary IRAP Rate
Abruzzo 3.9%
Basilicata 3.9%
Calabria 4.82%
Campania 4.97%
Emilia-Romagna 3.9%
Friuli Venezia Giulia 3.9%
Lazio 4.82%
Liguria 3.9%
Lombardy 3.9%
Marche 4.73%
Molise 4.73%
Piedmont 3.9%
Puglia 4.82%
Sardinia 3.9%
Sicily 4.82%
Tuscany 3.9%
Trentino Alto Adige 3.9%
Umbria 3.9%
Valle d’Aosta 3.9%
Veneto 3.9%

Businesses Operating in More Than One Italian Region

Where a business operates in more than one Italian Region, the IRAP taxable base may need to be allocated between the different Regions.

The allocation rules depend on the nature of the business activity and may involve factors such as:

  • employment costs in each Region
  • the location of employees
  • the duration of activity carried out in each Region
  • the existence of permanent establishments or operating locations

This means that a business may effectively become subject to more than one regional IRAP rate.

For larger businesses operating nationally across Italy, the allocation process can become relatively technical. Accounting for deferred taxes, particalry in the light of the fact permanent and timing differences

Is IRAP Deductible?

The current practical position is:

  • the IRAP tax itself is generally not directly creditable against IRES (formerly IRPEG) or IRPEF.
  • However, in certain circumstances, the IRAP paid may effectively become deductible as a business cost for income tax purposes.

Businesses may in some cases deduct from taxable income the portion of IRAP relating to e.g.:

  • employment costs
  • interest expenses
  • certain business costs

The precise deductibility depends on:

the type of taxpayer,
the accounting treatment adopted,
and the nature of the underlying expenses.

The rules have changed several times over the years and are quite technical in practice.

The Historical “Autonomous Organisation” Problem

For many years there was extensive litigation concerning whether a self-employed professional had sufficient “autonomous organisation” (“autonoma organizzazione”) to trigger IRAP liability.

The Italian courts issued a large number of decisions examining issues such as:

  • the use of employees
  • office organisation
  • equipment
  • collaborators
  • administrative support

The position often became uncertain and difficult to apply consistently in practice.

Fortunately, much of this historical complexity became less important after the abolition of IRAP for many individual taxpayers.

Conclusion

Although IRAP remains relevant for companies and larger business structures, it is far less significant today for many freelancers and individual professionals operating in Italy.

For many individuals, the key practical question is now relatively straightforward:

If you operate personally as a freelancer or sole proprietor, there is a good chance IRAP no longer applies to you.

Companies and incorporated businesses, however, will generally still need to consider IRAP as part of their ongoing Italian tax obligations.