GloBE Country Guide: Italy

Summary

Status Enacted Law
LawOn 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 DateAccounting periods beginning on or after December 31, 2023
IIRYes (2024)
UTPRYes 2025
QDMTTYes (2024)
Filing DeadlinesStandard
Safe HarboursTransitional CbCR, UTPR and QDMTT Safe Harbours

Contents
  1. Legislation
  2. General
  3. Differences to Model Rules
  4. Qualifying Domestic Minimum Top-Up Tax
  5. Administration and Filing
  6. Penalties

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