Professional assistance for foreign companies that need to establish and manage a permanent establishment in Italy, with support in the initial assessment, the appointment of a tax representative and ongoing compliance.
When a permanent establishment in Italy is needed
A foreign company that carries out business activities in Italy through a fixed place of business, such as a place of management, a branch, an office, a factory or a workshop, may create a permanent establishment in Italy for tax purposes, even without setting up a separate Italian company. The permanent establishment is defined by the Italian tax code (Article 162 of the TUIR) and represents an intermediate option between a simple representative office, which has no tax relevance, and a fully autonomous subsidiary such as an Srl. Identifying correctly whether an Italian activity qualifies as a permanent establishment is essential, since it determines specific registration, accounting and tax obligations.
How we assist your company
We help foreign companies assess which structure best fits their activity in Italy, whether a representative office, a permanent establishment or a subsidiary, and support the registration of the chosen structure with the Registrar of Companies, the tax authorities and, where relevant, social security bodies. Once the permanent establishment is operative, we assist with ongoing compliance, including VAT, direct taxes, statutory accounting and payroll for any local staff, acting as a stable point of reference for the parent company.
Who this service is for
Foreign companies planning a physical presence in Italy
For companies opening an office, a branch or a workshop in Italy without incorporating a separate subsidiary.
Companies that need to assess their tax position in Italy
For businesses that need to determine whether their Italian activities already create a permanent establishment for tax purposes.
Foreign groups requiring ongoing compliance for an Italian branch
For groups that already operate a permanent establishment in Italy and need continuous tax, accounting and payroll assistance.
What the service includes
The scope of our assistance depends on the structure your company chooses. We support both lighter, non-taxable presences and fully taxable structures, with services tailored to each option.
For a representative office
- Assessment that the planned activities remain within the preparatory or auxiliary scope that keeps the office outside the scope of direct taxation
- Registered address and management of official correspondence
- Assistance with the VAT position where the office’s activity has VAT relevance
- Ongoing monitoring of the activity, to flag if it evolves towards a permanent establishment or a subsidiary
For the domiciliation and day-to-day administrative aspects of a representative office, we also collaborate, when useful, with specialised partners such as ABSV Consulting Srl, to ensure correct and compliant management of the local presence.
For a subsidiary or a permanent establishment
- Assessment of the most suitable structure: permanent establishment or subsidiary
- Registration with the Registrar of Companies and the tax authorities
- Appointment as tax representative and registered office services, where needed
- VAT and direct tax compliance for the Italian permanent establishment or subsidiary
- Statutory accounting and periodic tax filings
- Payroll and social security management for local staff
- Ongoing coordination and reporting with the foreign parent company
How the process works
1. – Initial assessment of the Italian activity and the applicable structure
2. – Registration of the permanent establishment with the relevant authorities
3. – Set-up of tax, accounting and payroll compliance
4. – Ongoing assistance and periodic reporting
FAQ – Frequently asked questions
What is a permanent establishment in Italy?
It is a fixed place of business, such as a place of management, a branch, an office, a factory or a workshop, through which a foreign company carries out all or part of its activity in Italy, as defined by Article 162 of the Italian tax code (TUIR).
What is the difference between a permanent establishment and a subsidiary?
A permanent establishment has no separate legal personality, so the foreign parent company remains directly liable for its acts, while a subsidiary, such as an Srl, is a fully autonomous legal entity.
Does a permanent establishment need a tax representative in Italy?
Depending on the structure chosen and the activities carried out, a tax representative or a similar figure may be required to manage the relevant tax and administrative obligations in Italy.
What are the main tax obligations of a permanent establishment in Italy?
A permanent establishment is generally subject to Italian corporate income tax and regional tax on the income attributable to it, in addition to VAT compliance and statutory accounting obligations.
Assess whether your activity in Italy requires a permanent establishment
If your company is planning a physical presence in Italy or already operates locally, we can help you assess the correct structure and manage the registration and ongoing compliance of your permanent establishment.