On December 31, 2024, Ministerial Decree of December 27, 2024 was published in the Official Gazette. This implements Article 4.1-4.3 of the February 2023 OECD Administrative Guidance and some aspects of the June 2024 OECD Administrative Guidance on deferred taxation.
The Ministerial Decree of December 27, 2024 published in the Official Gazette on December 31, 2024 provides for a number of miscellaneous, but important aspects of the OECD Administrative Guidance that were not included in the original Minimum Tax Law.
On October 15, 2024, Italy issued Decree 11, of October 2024 on the calculation of the Substance-based Income Exclusion (SBIE) under Pillar 2. This includes all of the OECD Administrative Guidance on the SBIE.
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 (QDMTT).
On May 21, 2024, the Italian Ministry of Economy and Finance issued a Decree providing further details on the application of the Transitional Safe Harbours.
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