Italy: Restated 2023 Comparatives Do Not Remove a Group from the Pillar Two Scope Test

On 23 October 2026, Italy’s Revenue Agency published Response No. 188/2026, concluding that lower 2023 comparative revenue presented after adopting OIC 34 cannot replace the figures in the originally approved 2023 consolidated financial statements when applying the global minimum tax scope test for 2024.

The decision is relevant to groups close to the €750 million threshold whose reported turnover changes following a move from gross to net revenue recognition. The key distinction is between the accounts approved for the historical year and a later presentation of that year’s figures for comparison.

The ruling

The applicant had exceeded the threshold in 2022 and 2023. Its adoption of OIC 34 changed the presentation of meal-voucher agency activities to net commission revenue, and its restated 2023 comparative fell below the threshold. The Agency rejected using that lower comparative for the 2024 assessment. It relied on the comparative purpose of the adjustment under OIC 29 and the reference to revenue reported in approved consolidated accounts.

Member analysis: The accounting background, implications for scope assessments and practical review points are considered below.