GloBE Country Guide: Italy

Summary

Status	Enacted Law
Law	On October 15, 2024, Italy issued Decree 11 of October 2024 on the calculation of the Substance-based Income Exclusion under Pillar 2. On July 3, 2024, the Italian Ministry of Economy & Finance issued a Decree which contains the procedures for the implementation of the Qualified Domestic Minimum Top-up Tax. On May 21, 2024, Italy’s Ministry of Economy & Finance issued a Decree for the detailed application of the Transitional CbCR and UTPR Safe Harbours. Legislative Decree No. 209 of December 27, 2023
Effective Date	Accounting periods beginning on or after December 31, 2023
IIR	Yes (2024)
UTPR	Yes 2025
QDMTT	Yes (2024)
Filing Deadlines	Standard
Safe Harbours	Transitional CbCR, UTPR and QDMTT Safe Harbours

Legislation
General
Differences to Model Rules
Qualifying Domestic Minimum Top-Up Tax
Administration and Filing
Penalties

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Lee Hadnum

Lee is a qualified Chartered Accountant and Chartered Tax Adviser. A former Senior Tax Analyst at Bloomberg Tax, Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience. Lee's books have been recommended by The Times, The Guardian and The Telegraph.

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GloBE Country Guide: Italy

Summary

Contents

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Lee Hadnum