Italy: Procedure for obtaining hybrid mismatch penalty protection
Rules allowing taxpayers to obtain penalty protection relating to hybrid mismatch disputes by compiling certain documentary evidence
Procedure for obtaining hybrid mismatch penalty protection
Article 61 of Legislative Decree no. 209/2023 (the so-called “Internationalization Decree”), which implements part of the tax reform introduced by Law no. 111/2023 directing the government to reform the tax system (read TaxNewsFlash), includes rules allowing taxpayers to obtain penalty protection relating to hybrid mismatch disputes by compiling certain documentary evidence that they have carried out analyses to verify correct application of the hybrid mismatch rules.
Transitional rules are also provided for fiscal years prior to FY2023.
The precise content and form of the required documentation will be subsequently established by ministerial decree.
Read a January 2024 report [PDF 292 KB] prepared by the KPMG member firm in Italy
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