Resident entities that carry out a commercial, industrial or agricultural activity are subject to taxation on their profit. As a rule, the taxable profit of these entities is the sum of the net profit for the accounting period and the accretions to and decreases in net worth suffered in the same period and not reflected in this result, based on accounting records and possibly adjusted in accordance with specific tax rules.

Entities that do not carry out such activities are subject to taxation on the aggregate amount of the income subject to PIT (IRS), together with gratuity income (for these entities see Advance Ruling no. 325/2005 dated 14 November 2005).

For PEs, the taxable profit is established as outlined for resident entities that carry out a commercial, industrial or agricultural activity. In calculating taxable profit, general administrative expenses that are attributable to the PE may be deducted as costs.