Italy: Changes to cooperative compliance regime

New lower thresholds for taxpayers to qualify for the “cooperative compliance regime”

New lower thresholds for taxpayers to qualify for the “cooperative compliance regime”

A ministerial decree (published in the official gazette on 8 February 2022) provides new lower thresholds for taxpayers to qualify for the “cooperative compliance regime.”

The cooperative compliance regime, introduced by Legislative Decree no. 128/2015, is intended to increase the level of certainty about tax issues through dialogue, in order to arrive at a common assessment of conditions likely to generate tax risks.  Read a report (May 2019) [PDF 293 KB] describing the cooperative compliance regime for Italian permanent establishments.

Taxpayers may access the regime on a voluntary basis if they meet certain dimensional and organizational criteria including having a “tax control framework” in place.

Regarding the dimensional aspects, access to the regime was originally reserved for resident taxpayers and for non-resident taxpayers with a permanent establishment in Italy, with turnover or revenues, in both cases, of not less than €10 billion. This threshold was subsequently reduced to €5 billion for fiscal years 2020 and 2021.

The dimensional threshold has now been further reduced to €1 billion for 2022, 2023, and 2024. As a result, the number of taxpayers potentially eligible for the cooperative compliance regime has considerably increased.

Read a February 2022 report [PDF 221 KB] prepared by the KPMG member firm in Italy


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