LLC × residence calculator · Edition 2026.09
If you lived in Italy: how much tax you would pay on your LLC profit
The Italian tax agency does not recognise the US LLC's transparency: under art. 73.1.d) TUIR it treats it as an opaque company resident abroad, so the resident member is taxed only on withdrawal, as capital income at 26%, not every year on the profit as it is earned. Circolare 9/E/2015 (point 5.1) explains that the taxable base is net of the US tax already paid on that same profit, as if it were a real dividend from an opaque company.
Isaac Cubero · Checked on 14 September 2026 · worldwide income
At $100,000 of profit
On $100,000 of LLC profit, living in Italy, you would pay about $26,000 a year: a 26% effective rate.
worldwide income
| Capital income on withdrawal: Italy treats the US-transparent LLC as an opaque company (art. 73.1.d TUIR) and only taxes it on distribution | $26,000 |
| Estimated total | $26,000 |
Sources: Law 199 of 30 December 2025 (2026 Budget Law), art. 1: 23-33-43% IRPEF from 2026 (previously 23-35-43%) and the new-resident flat tax raised to EUR 300,000 · Ministry of Economy and Finance (MEF), 'Main measures of the 2026 Budget Law' · Italian Revenue Agency, Circular 9/E of 5 March 2015, point 5.1 'Profits distributed by transparent foreign entities' (art. 73(1)(d) TUIR) · Legislative Decree 117 of 19 June 2026 (new income tax Consolidated Text, in force since 4 Jul 2026), which recodifies the impatriati regime (art. 225) and the forfettario flat-rate regime (art. 232) · Fixed exchange rate 0.86 EUR/USD.
Rank 29 of 38 residences by effective rate at this profit.
- 2026 IRPEF scale: 23% up to €28,000, 33% from €28,000 to €50,000 and 43% above, after the second-bracket cut (previously 35%) approved by the 2026 Budget Law (Law 199/2025).
- The full LLC profit is withdrawn the same year it is earned and taxed as capital income at 26% (the Circolare 9/E/2015 reading), without netting the US tax already paid on that amount in the calculation.
- No regional or municipal surcharges, no INPS or gestione separata social security, no special regimes (impatriati, forfettario, new-resident flat tax).
- If the tax agency reclassifies the LLC as transparent by analogy with art. 5 TUIR (partnership), the profit would be taxed in full every year on the general scale (up to 43%) instead of the flat 26% on distribution; the official view (Circolare 9/E/2015, but also Ruling response 129/2023) is not unanimous in professional practice.
- The impatriati regime (D.Lgs. 209/2023 art. 5, folded since July 2026 into the new income tax Consolidated Text, D.Lgs. 117/2026 art. 225) gives a 50% exemption (60% with a minor child) up to €600,000/year for 5 years, but since 2024 it only covers employment and self-employed professional income, not business or capital income: the LLC dividend, as modelled here, probably does not qualify.
- The high-net-worth new-resident regime (art. 24-bis TUIR) replaces income tax on all foreign income, dividends and LLC profit included, with a flat annual fee: it rose from €100,000 to €200,000 in August 2024, and to €300,000/year for anyone moving residence from 1 Jan 2026 (same Law 199/2025); it only pays off with large profits.
- If you manage the LLC from Italy or your main client is Italian, the risk of esterovestizione or of the tax agency recasting the income as Italian self-employment or business income is real; the forfettario flat-rate regime (15%/5% up to €85,000 in revenue) is usually cheaper than running an LLC if you invoice directly from Italy yourself.
- Law 199 of 30 December 2025 (2026 Budget Law), art. 1: 23-33-43% IRPEF from 2026 (previously 23-35-43%) and the new-resident flat tax raised to EUR 300,000
- Ministry of Economy and Finance (MEF), 'Main measures of the 2026 Budget Law'
- Italian Revenue Agency, Circular 9/E of 5 March 2015, point 5.1 'Profits distributed by transparent foreign entities' (art. 73(1)(d) TUIR)
- Legislative Decree 117 of 19 June 2026 (new income tax Consolidated Text, in force since 4 Jul 2026), which recodifies the impatriati regime (art. 225) and the forfettario flat-rate regime (art. 232)
- Fixed exchange rate 0.86 EUR/USD.
At three profit levels
What you would pay in Italy depending on what your LLC earns.
| Annual profit | Estimated tax | Effective rate | You would keep |
|---|---|---|---|
| $50,000 | $13,000 | 26% | $37,000 |
| $100,000 | $26,000 | 26% | $74,000 |
| $250,000 | $65,000 | 26% | $185,000 |
And if it were not an LLC
The five cheapest structures from Italy, distributing all the profit.
| Structure | Corporate | Withholding | You, in Italy | Total |
|---|---|---|---|---|
| US LLC | $0 | $0 | $26,000 | 26%$26,000 |
| UAE free zone | $0 | $0 | $26,000 | 26%$26,000 |
| Hong Kong Ltd | $8,250 | $0 | $23,855 | 32.1%$32,105 |
| Bulgarian EOOD | $10,000 | $4,500 | $18,900 | 33.4%$33,400 |
| Georgian LLC | $15,000 | $4,250 | $17,850 | 37.1%$37,100 |
Frequently asked questions
Does a US LLC pay tax if I live in Italy?
The LLC pays no US federal tax if it has no US activity. The Italian tax agency does not recognise the US LLC's transparency: under art. 73.1.d) TUIR it treats it as an opaque company resident abroad, so the resident member is taxed only on withdrawal, as capital income at 26%, not every year on the profit as it is earned. Circolare 9/E/2015 (point 5.1) explains that the taxable base is net of the US tax already paid on that same profit, as if it were a real dividend from an opaque company.
How much would I pay in Italy on $100,000 of profit?
On $100,000 of LLC profit, living in Italy, you would pay about $26,000 a year: a 26% effective rate. The figure comes from applying capital income on withdrawal: italy treats the us-transparent llc as an opaque company (art. 73.1.d tuir) and only taxes it on distribution to the profit converted to EUR.
Is Italy a territorial country?
No: Italy taxes its residents' worldwide income. The LLC profit goes into your income tax under the country's rule (worldwide income).
Next
The figure is the start. The structure is the decision.
To see Italy against the other 37 residences: the full ladder.