Premial IRES 2025: Employment Requirements and Restrictions
With the Ministerial Decree of August 8, 2025, the essential conditions required to access the reduced 20% IRES rate for the 2025 tax period have been defined. These conditions, which concern company personnel, apply—by way of example—to taxpayers whose tax period coincides with the calendar year.
Below is a summary of the main personnel requirements for benefiting from the incentive:
- Employment retention: The number of Full-Time Equivalent units (FTEs) recorded in December 2025 must not be lower than the average of the previous three years. Specifically, for those whose year ends on December 31, the December 2025 figure must be compared with the simple arithmetic average for the period December 1, 2022 – November 30, 2025.
- Employment increase: The company must have made new hires of employees under open-ended (permanent) contracts, ensuring an increase of at least 1% compared to the average number of permanent employees employed in 2024, and in any case by no less than one unit.
- Cassa Integrazione (Wage Guarantee Fund): The period during which the company is prohibited from using the Wage Guarantee Fund (CIG), for the purpose of accessing the reduced 20% IRES rate for the 2025 tax period, coincides with the entire reference period used to verify employment requirements. In particular, the prohibition applies from December 1, 2022 to November 30, 2025, which is the period used to calculate the average number of Full-Time Equivalent units (FTEs) and to compare it with the December 2025 figure. Therefore, to benefit from this measure, the company must not have resorted to CIG in any month between December 1, 2022 and November 30, 2025.
LDP remains available for further clarification.
Have a nice day,
Arianna De Carlo
Labour Consultant, Head of the LDP Payroll Team