Observatory › Business and companies › Società di comodo (dormant companies) in the 2026 REDDITI return

Società di comodo (dormant 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 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 apply automatically, whereas disapplication requires proof of the objective circumstances that prevented the revenue threshold from being reached. Careful assessment heads off challenges during an audit.

• Non-operating companies – art. 30 of l. 724/1994.
• Modello REDDITI 2026 – the dormant-company schedule in section RS.