Insights · 21 minutes
Selling a hotel in Italy
Property, business or shares: in Italy three routes lead to a sale, and they cost different amounts. Since the 2026 budget act the choice falls out differently than it did the year before, and the most expensive clause of the contract is the one that allocates the price.
Thomas Uhlir, MBA · Published on September 23, 2026 · Last updated on September 23, 2026
In Italy a hotel is sold along one of three routes: the property alone, the business as an azienda, or the shares of the company that holds both. With a seller subject to VAT the first carries 3 percent imposta ipotecaria and 1 percent imposta catastale, the second a registration tax whose amount hangs on the price allocation in the contract, the third 200 euro.
Which of the three is the right one shifted on 1 January 2026. The reason sits in two paragraphs of a budget act, and it has rarely arrived in first conversations.
Anyone working with last year's calculation is calculating in the wrong direction.
Italy is not one market but five
For the 2025 calendar year ISTAT counts, in the Italian hotel industry, meaning the segment of the esercizi alberghieri, 98,814,514 arrivals and 288,181,878 overnight stays, 53.6 percent of them from guests not resident in Italy, across 33,281 businesses with 2,299,940 beds. Across all types of accommodation the foreign share of overnight stays is higher, at 56.3 percent according to the same database. The two figures do not belong side by side.
The distribution by category describes the market more precisely than any growth figure: 2,340 houses with one star, 4,948 with two, 15,065 with three, 6,874 with four and 809 with five. The growth happens at the top, at four stars since 2023 from a base of 6,416, at five stars from a base of 686.
In that movement lies the transaction market. What is sold is rarely the three star house that runs well. More often it is the house that a buyer wants to lift, and the price arises from his projection, built up as in What a hotel is worth.
For 2025 the Banca d'Italia reports spending by foreign travellers of 56.7 billion euro, 4.6 percent more than in 2024 in nominal terms. The largest source market is Germany with 15.6 percent.
The investment market stays small and concentrated. EY names a hotel investment volume of 2.5 billion euro for 2025, 19 percent above the previous year, of which 630 million in Rome; Rome, Milan, Venice and Florence carry 55 percent. Colliers arrives at 2.2 billion. The divergence comes out of the definition, which is why any statement here has to name its source.
With that the map is drawn. South Tyrol and the Alpine arc live on two seasons and on houses in family hands. Lake Garda draws German speaking private buyers. The Adriatic between Rimini and Ravenna is small scale, with a high investment backlog. Tuscany sells location and history, often as a resort with land. Only in Rome, Milan, Venice and Florence does institutional capital bid regularly.
Anyone transferring a market figure from one of those five markets to another arrives at a price that nobody pays. Which regions we handle is set out under Markets.
Before the price comes the question of what is actually being sold
In Italy a hotel carries the cadastral category D/2, alberghi e pensioni, and therefore counts as a fabbricato strumentale, a building used for business. What governs is the category at the moment of transfer, and it decides the whole tax calculation.
Where a private individual sells, a registration tax of 9 percent falls due under Tariffa part I art 1 DPR 131/1986, at least 1,000 euro. Where an undertaking sells, art 40 DPR 131/1986 applies: the imposta di registro, the registration tax, falls due only at the fixed amount, since 2014 at 200 euro.
In exchange two proportional taxes come on top. Tariffa art 1-bis of D.Lgs. 347/1990 charges the registration of transfers of ownership in immobili strumentali with 3 percent imposta ipotecaria, the mortgage registration tax, even where the transaction carries VAT; art 10 of the same decree charges the cadastral rewriting with 1 percent imposta catastale, the cadastral tax. Both go back to art 35 para 10-bis of D.L. 223/2006. The Agenzia delle Entrate, the Italian revenue agency, summarised the position in a case that concerned a complessa struttura alberghiera.
With VAT the exemption is the normal case. Art 10 no 8-ter DPR 633/1972 exempts the disposal of a fabbricato strumentale, with two exceptions: the sale by the construction or refurbishment company within five years of completion, and the option declared in the contract. The rate under art 16 DPR 633/1972 is 22 percent.
The option brings with it the reverse charge under art 17 para 6 lit a-bis DPR 633/1972, so no pre financing on the buyer's side, and it preserves the seller's right to deduct input tax.
A worked example on Lake Garda, two routes, two calculations
Worked example. A house on Lake Garda changes owner for 12 million euro, of which 10.5 million fall on the property, 1 million on the furniture and fittings and 500,000 euro on goodwill.
Route one, the sale of the property by the owning company: 200 euro of registration tax, 3 percent imposta ipotecaria on 10.5 million and 1 percent imposta catastale, together around 420,000 euro.
Route two, the sale of the business as an azienda, meaning the business as a going concern: under art 2 para 3 lit b DPR 633/1972 the transaction falls outside the scope of VAT and carries the proportional registration tax. With the price allocation shown, that is 9 percent on the property portion, 3 percent on the movable assets and the matching rate on the rest. The proportional ipo-catastale charge remains alongside, because the Agenzia delle Entrate applies it to property inside an azienda as well.
Both calculations hold up, and they lead to different amounts. Which one applies is decided in the drafting of the contract, and before the first figure.
Since 2025 the price allocation is the most expensive clause in the contract
Art 23 para 4 DPR 131/1986 was recast by D.Lgs. 139/2024 with effect from 1 January 2025. It requires the purchase price of an azienda to be allocated to the individual assets on the basis of an allocation shown in the contract or in its annexes.
The last sentence of the provision is the expensive one. Where the allocation is missing, para 1 applies: the highest rate on the entire purchase price.
For a hotel business that means 9 percent on everything, on the furniture, the stock and the goodwill as well. On a purchase price of 12 million euro that comes to 1.08 million euro.
The basis of assessment sits in art 51 para 2 DPR 131/1986: the total common value including goodwill, less the liabilities apparent from the mandatory books. The appropriateness of the allocation is open to review.
In a sale we handled, the draft contract for a hotel business was in its final version when the buyer's chartered accountant asked about the annex with the price allocation. There was none. The draft named a total price and listed the assets taken over, without values.
Putting that right cost two weeks and a valuation by a third party. The alternative would have cost more: without the allocation the registration tax would have hit the whole purchase price at the rate for property, including furniture and goodwill. The seller had never seen that annex as a tax question. To him it was an attachment.
The annex to the purchase contract is a subject of negotiation worth a six figure sum. It belongs in the preparation and not in the week before the notary appointment.
On the seller's side the calculation turned in 2026
Corporate income tax stands at 24 percent under art 77 TUIR, the consolidated income tax act. That is the easy half of the statement.
The other half sits in art 86 para 4 TUIR. Up to and including 2025 a capital gain could be spread over five years where the asset had been held for at least three years. The 2026 budget act, Legge 199/2025, restricted that spread in art 1 paras 42 and 43 to the disposal of an azienda or of a branch of a business, for gains from the tax period following 31 December 2025.
In practice that means the sale of the hotel property alone is taxed in full in the year of sale, while the same sale as a business with a three year holding period can be spread over five. For a seller with an eight figure gain that is a liquidity difference measured in years, and the reason why a structure devised in 2025 belongs recalculated. The trade off is set out in Asset deal or share deal.
With IRAP, the regional tax on productive activities, the position is split. Art 5 para 1 D.Lgs. 446/1997 takes extraordinary items out of the transfer of undertakings or branches of undertakings out of the basis of assessment; the gain from a cessione d'azienda, the transfer of a business, is therefore free of IRAP. On the sale of the individual business property the treatment is contested; the Cassazione, the Court of Cassation, decided against inclusion in 2026, but that is a single decision. The standard rate stands at 3.9 percent, with a regional margin of 0.92 percentage points.
Where a private individual sells, a five year period applies. Art 67 para 1 lit b TUIR catches gains on property acquired or completed not more than five years earlier. Within the period the substitute tax of 26 percent under art 1 para 496 Legge 266/2005 is available at the notary. Undertakings are excluded.
The quota costs 200 euro, and the rest is written elsewhere
Where the company is sold instead of the house, the indirect tax is a footnote. Tariffa part I art 11 DPR 131/1986 charges transfers of shares with the fixed registration tax of 200 euro. The form is governed by art 2470 Codice Civile: certified signature, lodgement with the commercial register within 30 days.
The question that hangs on it is the one about recharacterisation. Art 20 DPR 131/1986 in the 2017 version has regard solely to the deed submitted for registration and excludes extrinsic circumstances and linked deeds. The Corte Costituzionale, the Constitutional Court, upheld that in 2020, in a case in which the tax administration had recharacterised exactly that chain: newco, contribution of business branches, sale of the quota.
A residual risk remains. The abuse of law provision in art 10-bis Legge 212/2000 catches arrangements without economic substance which, while formally complying with the law, produce unjustified tax advantages.
On the seller's side the participation exemption decides. Art 87 TUIR exempts 95 percent of capital gains on shareholdings where four conditions come together, among them uninterrupted holding from the first day of the twelfth month before the disposal.
The fourth is the decisive one for hotel companies. It is treated as conclusively unmet where the assets consist predominantly of property serving neither trade nor production; buildings used directly in the company's own business are excepted. A company that runs the hotel itself can therefore reach the exemption, while a pure property holding company cannot.
Natural persons pay 26 percent on the gain from a sale of shares.
Art 2112 leaves the staff no choice, art 47 leaves the seller 25 days
Art 2112 Codice Civile is shorter and stricter than its German and Austrian counterparts. On a transfer of undertaking the employment relationship continues with the acquirer, and the employee keeps every right arising from it. The provision knows no right to object.
Transferor and acquirer are jointly and severally liable for all claims existing at the moment of transfer; the transferor escapes that liability only through a conciliation procedure. Where the working conditions deteriorate materially, the employee may resign within three months with the consequences of a giusta causa, a justified resignation for cause.
The most important paragraph for hotels is the fifth. It defines the transfer of undertaking broadly as any transaction which, while preserving the identity, changes the ownership of an organised economic activity, and it names usufruct and the leasing of a business expressly. The leasing itself, or its termination, already triggers the legal consequences. What else hangs on a lease is set out in Lease, management or own operation.
The procedure is governed by art 47 Legge 428/1990. Where there are more than fifteen employees, transferor and acquirer have to notify the union representatives in writing at least 25 days in advance of when the transfer will take place, why, and with what consequences.
The period runs from the earlier of two moments: the execution of the deed or a binding agreement. A signed letter of intent therefore starts the clock long before anybody sits at the notary. Anyone who does not plan for that negotiates the price with a workforce that has already been informed. Breaches of that duty count as anti union conduct under art 28 Legge 300/1970.
A second point concerns the debts. Under art 2560 Codice Civile the transferor is released from business debts that arose before the transfer only where the creditors agree; the acquirer is liable to the extent they appear from the mandatory books. The bookkeeping is therefore the boundary of the buyer's risk.
Before anything is signed, third parties have a say
Three rights of third parties can delay or end a hotel sale, and all three run on periods that nobody can negotiate.
The first is the tenant's right of pre emption. On a transfer for consideration of a let commercial property, the landlord has to inform him under art 38 Legge 392/1978 by a served deed stating the price as a figure; the right is exercised within 60 days. Where the notification is omitted, or where the price stated exceeds the price recorded in the deed, the tenant may buy the property back under art 39 within six months of registration.
On the leasing of a business those institutions do not apply; in 2024 the Cassazione refused to recharacterise a lease over a tourism business branch as a commercial tenancy.
The second right is the state's. For listed buildings, art 59 of the Codice dei beni culturali, the heritage code, requires every transfer of ownership to be notified to the superintendent within 30 days; where a mandatory item is missing, the notification counts as not made. The right of pre emption is exercised under art 61 within 60 days of receipt, and within 180 days where the notification was omitted or incomplete, and during the period the deed of disposal is subject to a condition precedent. Under art 164 disposals in breach of that are void. For a historic house in Florence or Venice the denuntiatio, the notification, is therefore a condition of validity.
The third, the agricultural tenant's right of pre emption under art 8 Legge 590/1965, regularly does not apply to hotel plots: it does not exist for land zoned for building, industrial or tourism use. With resorts holding larger areas of land the zoning of the parcels belongs checked all the same.
Above all of that stands the form. Art 2556 Codice Civile requires written form for the azienda and obliges the notary to lodge the contract with the commercial register within 30 days.
On the beach ownership ends, and in 2027 the concession ends
Anyone selling a house on the Adriatic, in Liguria or in Sicily is not selling the beach with it. It belongs to the maritime state property and is used through a concessione demaniale, a state maritime concession, granted for a limited term under art 36 of the Codice della Navigazione.
On a change of owner that becomes the critical point. Art 46 requires the authorisation of the granting authority for another party to step into the concession, including for the acquirer of the structures erected on the state property. Without that authorisation the buyer does not become concessionaire, and he has acquired a hotel without a beach. Art 49 sets the second limit: structures that cannot be removed fall to the state without compensation on termination, unless the deed of concession provides otherwise.
Above that sits the dispute under European law. Under art 3 Legge 118/2022 existing concessions for tourism, leisure and sporting purposes keep their effect until 30 September 2027, so that the award procedures can run. A postponement is possible, not beyond 31 March 2028.
The new concessions run five to twenty years, measured by the amortisation of the investments provided for in the financial plan. The outgoing concessionaire receives compensation for investments made and not yet amortised, plus reasonable interest; the new concessionaire bears it, and the concession relationship comes about only once 20 percent of it has been paid.
In August 2026 the Consiglio di Stato, the Council of State, decided that the cut off date is a technical extension of limited effect and that municipalities may close the procedures earlier. On that reading there is no blanket claim to reimbursement, and the burden of proof lies with the outgoing concessionaire.
For a sale before 2027 that means two things. The remaining term of the concession belongs in the buyer's projection, and the records of the investments belong put in order while the seller can still assemble them himself.
The region awards the stars, not Rome
Since the constitutional reform of 2001 tourism has fallen within the residual competence of the regions. In 2012 the Corte Costituzionale declared unconstitutional those articles of the Codice del Turismo which assigned classification and its standards to the state.
What remains is the DPCM of 21 October 2008. It defines national minimum standards for classification by stars, allows the regions stricter standards, and applies only to new openings and to conversions requiring a permit. Existing houses do not have to retrofit.
What that means is shown by a comparison of two regions. In South Tyrol the mayor classifies on the basis of a binding opinion of the provincial tourism councillor, from three stars superior after an inspection by an independent commission, and the classification applies without a time limit. In Tuscany it has been made by self declaration in the operating notification since the Testo unico del turismo of 2024, the consolidated tourism act.
Anyone pricing the stars of a house into the valuation therefore checks first in which of the two systems they were awarded.
In South Tyrol the house sits under three restrictions
A widespread misconception first: there is no residence requirement for the acquisition of a hotel property in South Tyrol. The much quoted convenzionamento under art 39 of provincial law 9/2018 binds the occupation and letting of dwellings and does not concern hotels.
The actual restrictions weigh more heavily. The first is the bed ceiling under art 34 para 6, determined by the overnight stays reported for a day of the year 2019 chosen by the business. Without an allocation of beds by the municipality there is no permit that increases them. Anyone accommodating more guests than permitted from 2023 pays a hundred times the tourist tax per overnight stay.
The second is the use restriction. Under art 36 para 3, outside the settlement area, building volume with a hospitality use designation may not be put to any other use, not even on demolition and reconstruction. The conversion value does not exist there.
The third is the sharpest. Anyone who obtained approval for an extension in derogation from the planning instruments gave an undertaking for it under art 35 para 2, on the basis of which two things were noted in the land register: a twenty year use restriction tied to the hospitality activity and, without a time limit, the indivisibility of operating buildings and ancillary areas. Any separation needs a prior clearance certificate from the provincial tourism department, and the indivisibility outlives the use restriction. Anyone who wants to sell an ancillary area or a staff house separately checks the land register first and the price second.
Restrictions of that kind exist in other regions too, and they are in motion. In October 2025 the Corte Costituzionale declared the Ligurian rule unconstitutional in so far as it does not permit an application for release where economic unsustainability is demonstrated. Formally that binds only Liguria, but it sets a standard.
Who buys in Italy, and why 1 January 2027 is in the calendar
The circle of buyers is broader than in Austria or Switzerland and unevenly distributed. In Rome, Milan, Venice and Florence international funds, operator groups and family offices bid; cross border capital supplied 53 percent of the volume in 2025 according to EY. In the resort locations private investors buy, along with regional groups and, on Lake Garda as in South Tyrol, German speaking acquirers.
For sellers the same rule applies as in every tight market: the list of those who can seriously examine a house is shorter than the list of those who would look at it. How we build such a list is set out under Transaction, the assessment that precedes it under Valuation and feasibility. The comparison with the other side of the Adriatic is in Selling a hotel in Croatia, the one with the Alps in Selling a hotel in Austria.
That leaves the date. Every provision of DPR 131/1986 and DPR 633/1972 cited here carries, in the official body of norms, the note that it applies until 31 December 2026. On 1 January 2027 new testi unici, consolidated acts, enter into force: D.Lgs. 123/2025 for the indirect taxes, D.Lgs. 10/2026 for VAT.
What that means does not appear here, because it cannot be said responsibly without examining the new texts. What can be said: a sale process that starts today and runs for twelve months ends under a different set of rules.
Italy rewards sellers who settle their structure early and punishes everyone else with a tax bill that cannot be changed afterwards. Which of the three routes comes into question for your house we clarify before any further step, confidentially.
Sources
This article reflects the position as at 23 September 2026. It does not replace tax or legal advice; every individual case needs review by a commercialista, a lawyer or a notary.
- DPR 131/1986, Testo unico imposta di registro (consolidated registration tax act), Artt. 20, 23, 40, 51 and Tariffa, Normattiva, 2026. https://www.normattiva.it/uri-res/N2Ls?urn:nir:presidente.repubblica:decreto:1986-04-26;131
- DPR 633/1972, Testo unico IVA (consolidated VAT act), Artt. 2, 10, 16 and 17, Normattiva, 2026. https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1972-10-26;633
- D.Lgs. 347/1990, imposte ipotecaria e catastale (mortgage registration and cadastral taxes), Art. 10 and Tariffa Art. 1-bis, Normattiva, 2026. https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:1990-10-31;347
- D.L. 223/2006, Art. 35 comma 10-bis, Normattiva, 2026. https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legge:2006-07-04;223~art35
- D.L. 104/2013, Art. 26, Normattiva, 2026. https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legge:2013-08-12;104~art26
- Quadro generale delle categorie catastali (general table of cadastral categories), Agenzia delle Entrate, 2026. https://www.agenziaentrate.gov.it/portale/documents/20143/257829/Allegato%20quadro%20generale%20categorie_QuadroGeneraleCategorie.pdf/caf80eb7-3b75-037f-02ee-93d47b1e9df4
- Il trasferimento di bene strumentale paga ipo-catastale proporzionali (transfers of business assets carry proportional ipo-cadastral taxes), FiscoOggi, Agenzia delle Entrate, 2021. https://www.fiscooggi.it/portale/-/il-trasferimento-di-bene-strumentale-paga-ipo-catastale-proporzionali
- Artt. 2112, 2470, 2556 and 2560 Codice Civile (Civil Code), Brocardi.it, 2026. https://www.brocardi.it/codice-civile/libro-quinto/titolo-ii/capo-i/sezione-iii/art2112.html
- Legge 428/1990, Art. 47, Normattiva, 2026. https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:legge:1990;428~art47
- DPR 917/1986, TUIR (consolidated income tax act), Art. 86, Normattiva, 2026. https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1986-12-22;917~art86
- Artt. 67, 77, 86 and 87 TUIR with notes on Legge 199/2025, Brocardi.it, 2026. https://www.brocardi.it/testo-unico-imposte-redditi/titolo-ii/capo-ii/sezione-i/art86.html
- D.Lgs. 446/1997, IRAP (regional tax on productive activities), Artt. 5 and 16, Normattiva, 2026. https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:1997-12-15;446~art5
- Tassazione plusvalenze immobiliari (taxation of capital gains on property), Agenzia delle Entrate, 2026. https://www.agenziaentrate.gov.it/portale/schede/pagamenti/tassazioneplusvalenze/cosa-tassazione-plusvalenze-immobiliari
- Corte Costituzionale, Sentenza 158/2020 on Art. 20 DPR 131/1986, reproduced by Studio Cerbone, 2020. https://www.studiocerbone.com/corte-costituzionale-sentenza-21-luglio-2020-n-158-non-fondate-le-questioni-di-legittimita-costituzionale-dellart-20-del-decreto-del-presidente-della-repubblica-26-aprile-1986-n-131/
- Legge 212/2000, Art. 10-bis, Normattiva, 2026. https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:legge:2000-07-27;212~art10bis
- Artt. 35, 38, 39 and 41 Legge 392/1978, Brocardi.it, 2026. https://www.brocardi.it/legge-equo-canone/titolo-i/capo-ii/art38.html
- Cassazione, Sez. III, ordinanza 3550/2024, affitto di ramo d'azienda (leasing of a business branch), commentary LexCED, 2025. https://www.lexced.com/giurisprudenza-civile/affitto-ramo-dazienda-quando-non-e-locazione/
- Artt. 59, 61 and 164 D.Lgs. 42/2004, Codice dei beni culturali e del paesaggio (heritage and landscape code), Brocardi.it, 2026. https://www.brocardi.it/codice-dei-beni-culturali-e-del-paesaggio/parte-seconda/titolo-i/capo-iv/sezione-i/art59.html
- Legge 590/1965, Art. 8, Normattiva, 2026. https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:legge:1965-05-26;590~art8
- Artt. 36, 46 and 49 Codice della navigazione (navigation code), LexCED, 2026. https://www.lexced.com/codice-navigazione/articolo/46/
- Legge 118/2022, Artt. 3 and 4, consolidated version, Normattiva, 2026. https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:legge:2022-08-05;118~art3
- D.L. 131/2024, Art. 1, Normattiva, 2026. https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legge:2024-09-16;131~art1
- Consiglio di Stato, Sez. VII, sentenza 6539 of 18 August 2026, commentary La Settimana Giuridica, 2026. https://lasettimanagiuridica.it/2026/08/29/concessioni-balneari-il-consiglio-di-stato-sulla-natura-del-termine-del-30-settembre-2027-e-sulloperativita-degli-indennizzi-agli-operatori-uscenti/
- Corte Costituzionale, Sentenza 80/2012 on the competence for classification, Gazzetta Ufficiale, 2012. https://www.gazzettaufficiale.it/atto/corte_costituzionale/caricaDettaglioAtto/originario?atto.dataPubblicazioneGazzetta=2012-04-11&atto.codiceRedazionale=T-120080
- DPCM 21 ottobre 2008, standard minimi per la classificazione degli alberghi (minimum standards for hotel classification), Gazzetta Ufficiale 34, 2009. https://www.gazzettaufficiale.it/eli/id/2009/02/11/09A01326/sg
- Legge regionale Toscana 61/2024, Testo unico del turismo (consolidated tourism act), Artt. 51 and 148, Consiglio regionale della Toscana, 2025. https://raccoltanormativa.consiglio.regione.toscana.it/articolo?urndoc=urn:nir:regione.toscana:legge:2024-12-31;61
- Landesgesetz 9/2018, Raum und Landschaft (provincial act on space and landscape), Artt. 34, 35, 36 and 39, coordinated text, Autonomous Province of Bolzano. https://assets-eu-01.kc-usercontent.com/e90ea1ed-9101-0155-579f-5243d49e1f43/eea1a7ae-4d6f-4fe2-b0ef-ae1926bc6330/Koordinierter%20Text%20Landesgesetz%20vom%2010.%20Juli%202018%2C%20Nr.%209.pdf
- Corte Costituzionale, Sentenza 143/2025 on the Ligurian vincolo alberghiero (hotel use restriction), 2025. https://www.cortecostituzionale.it/scheda-pronuncia/2025/143
- Flussi turistici, IV trimestre 2025 (tourism flows, fourth quarter 2025), with the annual rates of change for 2025, ISTAT, 9 March 2026. https://www.istat.it/comunicato-stampa/flussi-turistici-iv-trimestre-2025/
- Capacità e movimento dei clienti negli esercizi ricettivi (capacity and movement of guests in accommodation businesses), annual values 2025 for esercizi alberghieri and for all types of accommodation, Dataflow IT1:122_54, ISTAT, as at 11 September 2026. https://esploradati.istat.it/
- Indagine sul turismo internazionale 2025 (survey on international tourism 2025), Banca d'Italia, 26 June 2026. https://www.bancaditalia.it/pubblicazioni/indagine-turismo-internazionale/2026-indagine-turismo-internazionale/statistiche_ITI_26062026.pdf
- EY Italy Hotel Investment Report 2025, EY Italia, 16 February 2026. https://www.ey.com/it_it/newsroom/2026/02/investimenti-alberghieri-in-crescita-in-italia-nel-2025
- Colliers Italia, investimenti alberghieri 2025 (hotel investment 2025), press release reproduced by Federturismo Confindustria, 2026. https://www.federturismo.it/it/area-stampa/articoli-interviste/595-news/news-2026/22206-hotels-leisure-colliers-italia-in-italia-nel-2025-gli-investimenti-nel-settore-alberghiero-sono-cresciuti-del-18.html
Frequently asked questions
Which taxes arise on the purchase of a hotel property in Italy?
A hotel carries the cadastral category D/2 and counts as a fabbricato strumentale, a building used for business. Where a seller subject to VAT sells, the imposta di registro, the registration tax, falls due only at the fixed amount of 200 euro, but 3 percent imposta ipotecaria and 1 percent imposta catastale come on top. Where a private individual sells, it is 9 percent registration tax, at least 1,000 euro.
When does the sale of a hotel carry Italian VAT?
Art 10 no 8-ter DPR 633/1972 exempts the disposal of a fabbricato strumentale. It is taxable only where the construction or refurbishment company sells within five years of completion, or where the seller opts expressly for taxation in the contract. The rate is 22 percent, so the exemption is the rule and the charge the exception.
When does the reverse charge apply on an Italian hotel sale?
Only where the option is exercised. Art 17 para 6 lit a-bis DPR 633/1972 extends the reverse charge to disposals of buildings under art 10 no 8-bis and 8-ter for which the seller has opted for taxation in the contract. Where a construction company sells within the five year period, it invoices the tax in the normal way.
What form does the sale of a hotel business require?
Art 2556 Codice Civile requires written form for registered undertakings and reserves the form prescribed for the individual assets. The contract is to be made as a public deed or as a certified private deed, and the notary who records it has to lodge it for entry in the commercial register within 30 days of execution.
Why does the price allocation in the contract matter so much?
Because without it the highest rate applies to everything. Art 23 para 4 DPR 131/1986 in the version in force since 1 January 2025 requires an allocation of the purchase price to the individual assets, shown in the contract or in its annexes. Where it is missing, para 1 applies and the whole purchase price is charged at 9 percent.
How is the capital gain of an Italian company taxed?
At 24 percent IRES, the corporate income tax, under art 77 TUIR. The spread over five years under art 86 para 4 TUIR applies, from the tax period following 31 December 2025, only to the disposal of an azienda, a business as a going concern, or of a branch of one held for at least three years. For individual fixed assets the 2026 budget act abolished it.
Does IRAP arise on the sale of a hotel business?
Not on the disposal of an azienda. Art 5 para 1 D.Lgs. 446/1997 expressly takes extraordinary items out of the transfer of undertakings or branches of undertakings out of the basis of assessment. On the sale of the individual business property the position is contested; the standard rate of this regional tax on productive activities is 3.9 percent, and the regions may depart from it.
What does a private individual pay on the sale of a hotel property?
The gain is taxable under art 67 para 1 lit b TUIR only where no more than five years lie between acquisition or completion and sale. In that case the seller may elect at the notary for the substitute tax of 26 percent under art 1 para 496 Legge 266/2005. For undertakings that option is not available at all.
What does the sale of shares in an Italian S.r.l. cost?
The registration tax falls due only at the fixed amount under Tariffa part I art 11 DPR 131/1986, since 2014 at 200 euro. Under art 2470 Codice Civile the transfer deed needs a certified signature and is to be lodged with the commercial register within 30 days. There is no proportional tax on the price of the shareholding.
Can the revenue agency recharacterise a share sale as a sale of the business?
Under art 20 DPR 131/1986 in the 2017 version, regard is had solely to the deed submitted for registration, without extrinsic circumstances and linked deeds. The Corte Costituzionale, the Constitutional Court, upheld that version in 2020. A residual risk remains through the general abuse of law provision in art 10-bis Legge 212/2000.
What applies to the employees on a transfer of undertaking?
Under art 2112 Codice Civile the employment relationship continues with the acquirer, and the employee keeps every right arising from it. Transferor and acquirer are jointly and severally liable for existing claims. The transfer is no ground for dismissal. The provision expressly covers usufruct and the leasing of a business as well.
From what size must the sale be notified to the trade unions?
From more than fifteen employees in the undertaking being transferred. Art 47 Legge 428/1990 requires written notification at least 25 days before the deed is executed or before a binding agreement, whichever comes first. A breach of that duty counts as anti union conduct under art 28 Legge 300/1970.
What happens to a beach concession on a sale?
It does not pass automatically. Art 46 Codice della Navigazione requires the authorisation of the granting authority; without it even the acquirer of the structures erected on the state property does not step into the concession. On termination, structures that cannot be removed fall to the state without compensation under art 49.
How many hotels does Italy count?
For 2025 ISTAT reports 33,281 accommodation businesses in the hotel industry with 2,299,940 beds. By category there are 2,340 houses with one star, 4,948 with two, 15,065 with three, 6,874 with four and 809 with five stars. The number of four and five star houses has grown without interruption since 2023.
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