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      The Italian government recently ratified two international agreements affecting the movement of individuals between Italy, Moldova, and Kosovo.

      The Italian Parliament approved, and the President of the Republic promulgated, a law authorizing the ratification of the Convention with the Republic of Kosovo for the elimination of double taxation on income and the prevention of tax evasion and avoidance, which will enter into force at a future date.1

      Additionally, the Social Security Agreement between Italy and Moldova entered into force on 1 September 2025.2

      WHY THIS MATTERS

      These developments have significant implications for organizations, HR leaders, payroll managers, and globally mobile employees with connections to Italy, Moldova, or Kosovo.

      The double taxation convention with Kosovo clarifies tax residency rules, mitigates double taxation of income, and introduces anti-avoidance measures, thereby supporting compliance, assignment planning, and cost management for cross-border employment.

      The social security agreement with Moldova establishes coordinated recognition of pension and benefit entitlements, reduces the risk of double contributions, and enhances social protection for internationally mobile employees, their families, and survivors. 

      Key Highlights

      Italy/Kosovo Double Taxation  Agreement

      • Legislative status: The Italian Parliament and President approved the law authorizing ratification of the convention, signed at Pristina on 22 June 2021.
      • Scope: The convention eliminates double taxation on income and introduces measures to prevent tax evasion and avoidance between Italy and Kosovo.
      • Next steps: The convention will enter into force at a future date upon exchange of ratification instruments between Italy and Kosovo, in accordance with its provisions.

      Italy/Moldova Social Security Agreement

      • Entry into force: 1 September 2025, following ratification by Law No. 162 of 23, June 2025, and publication in the Official Gazette.
      • Italian scope: Includes pensions and benefits under the General Compulsory Insurance (Assicurazione Generale Obbligatoria, AGO), special schemes for self-employed workers, the Separate Management scheme, exclusive and substitute regimes managed by the National Social Security Institute (INPS), and benefits from the National Institute for Insurance against Workplace Accidents (INAIL).
      • Moldovan scope: Covers age pensions, disability pensions (arising from general illness or occupational causes), survivor pensions, and benefits for workplace injuries and occupational diseases.
      • Beneficiaries: Applies to individuals subject to the legislation of either or both countries, their family members and survivors, refugees, and stateless people.
      • Purpose: Coordinates coverage allows aggregation of insurance periods and reduces the risk of double contributions.
      • The agreement applies to benefit claims submitted from 1 September 2025. Insurance periods completed before this date will be considered, but no entitlement to benefits is granted for periods prior to entry into force. Rights to benefits may arise under this agreement, even if the insured event occurred before the entry into force of this agreement.

      KPMG INSIGHTS

      The agreements strengthen the legal and administrative frameworks governing cross-border work and taxation involving Italy, Moldova, and Kosovo. The Social Security Agreement with Moldova secures benefit entitlements and minimizes compliance risks for mobile employees and employers, while the Double Taxation Convention with Kosovo will reduce fiscal uncertainty, administrative complexity, and the risk of double taxation.

      In light of the changes, organizations, employers, and companies may:

      • Organizations may wish to review their cross-border assignment, payroll, and benefit planning for employees affected by these agreements.
      • Employers may wish to update internal policies and inform affected employees of their new rights and obligations under both frameworks.
      • Companies may wish to consult with qualified social security and tax advisers to comply with the agreements as they become operational.
      FOOTNOTES:

      1  (In Italian) Gazzetta Ufficiale, Realizzazione Istituto Poligrafico e Zecca dello Stato S.p.A., DTA ratification with Kosovo, published on 16 October 2025.

      2  (In Italian) Portale Inps - Sicurezza sociale internazionale: Accordo bilaterale con la Repubblica di Moldova, INPS website, published on 16 February 2025, last updated: 4 November 2025. 

      Contacts

      stefania-quaglia
      Stefania Quaglia

      Partner

      KPMG in Italy

      pierluigi-zucchelli
      Pierluigi Zucchelli

      Associate Partner, KPMG Italy

      KPMG in Italy

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      The information contained in this newsletter was submitted by the KPMG International member firm in Italy.

      GMS Flash Alert is a Global Mobility Services publication of the KPMG LLP Washington National Tax practice. 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.

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