Opportunities For Innovative Start-Ups

StarTax | Tax Notes Dedicated to Start-Ups

Italiano: Le Opportunità Per Le Start-Ups Innovative


Innovative Start-Ups are exempt from regulations on dummy companies, including those on companies registering systematic losses.

  • As a result, Start-Ups do not need to undergo operational testing to verify their inactivity status.
  • Tax penalties applied to the so-called dummy companies do not apply to Start-Ups (increased IRES rate – restated IRAP tax base).

Innovative Start-Ups (and certified incubators) are exempt from paying:

  • Annual fees to the Chambers of Commerce
  • Other registration fees and duty stamps usually owed to register with the Business Register (and also further obligations to fulfill, e.g. filing with annual financial statements and deed for capital increases)



The memorandum of association can set forth specific elements to make Start-Ups in S.r.l. (llc) more similar to S.p.A. (plc):
It is possible to:

  • create categories of shares with particular rights (e.g. voting rights non-proportional to the participation in the capital – rights diversified in terms of administration and allocation of profits – limited voting rights)
  • carry out transactions on one's shares in implementing incentive plans incentive plans that provide for the allocation of shares to employees/collaborators, suppliers, etc. (the so-called "stock options" and "work for equity")
  • issue participating financial instruments (with property and/or administrative rights)
  • offer capital shares to the public (crowdfunding)

Would you like to know more? Contact us!

Orrick Tax Group
Paolo Tartaglia
[email protected]

tel. +39 02 4541 3800