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GloBE Country Guide: Italy

Summary

Status Enacted Law
LawOn December 31, 2024, Ministerial Decree of December 27, 2024 was published in the Official Gazette. This implements the OECD Administrative Guidance on the treatment of deferred taxation generated in the period prior to the implementation of the GloBE rules.

On December 30, 2024, Ministerial Decree of December 20, 2024 was published in the Official Gazette. This addresses miscellaneous aspects of the GloBE Rules/Administrative Guidance (including the Forex Hedge election, debt release election and sovereign wealth funds).

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 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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