Observatory › Business and companies › Società di comodo (non-operating companies) in the 2026 REDDITI return

Società di comodo (non-operating companies) in the 2026 REDDITI return

The operating test, the grounds for exclusion and for disapplication: how to handle the rules on non-operating companies correctly in the tax return.

The rules on non-operating companies affect the minimum taxable income, the IRAP base and the use of the VAT credit, with significant consequences at the return stage.

The operating test

Comparing actual revenue with the deemed revenue obtained by applying the statutory coefficients to the company’s assets, both taken as the average of the current year and the two preceding years (art. 30(2) of l. 724/1994), determines whether the company passes the test. The outcome governs whether a minimum income must be declared and the restrictions that follow.

Exclusions and disapplication

The grounds for exclusion in art. 30(1) and the grounds for disapplication identified by the Revenue Agency Director’s measure of 14 February 2008 (prot. 23681), as supplemented by the measure of 11 June 2012 (prot. 2012/87956), apply automatically; in other cases disapplication requires proof of the objective circumstances that prevented the revenue threshold from being reached, either through a ruling request (interpello) under art. 30(4-bis) or, failing that, by reporting it separately in the income tax return (art. 30(4-quater)). A careful, documented assessment reduces the risk of challenges during an audit.

• Non-operating companies: article 30 of Law no. 724/1994.
• Modello REDDITI 2026: the schedule for non-operating companies in section RS.