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
The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.