Italy: Advance rulings, certainty for taxpayers

Certainty for taxpayers in Italy, advance rulings

A legislative decree that is intended to provide rules allowing for legal certainty in dealings between the tax authority and taxpayers includes new provisions that were effective 2 September 2015, as well as other measures that will apply beginning 1 October 2015. Included in the provisions are definitions of certain terms, including “tax avoidance,” and rules on the statute of limitations for assessment of income tax and value added tax (VAT).


Related content

The new provisions do not provide an exhaustive list of transactions subject to the anti-avoidance test, and the rules apply to all taxes—income tax and other direct taxes—but not customs duties. Taxpayers may seek an advance ruling from the tax authority as to whether their transactions fall under the abuse of law provisions.

large taxpayer program

A new tax compliance regime is introduced, aimed at increasing communication and cooperation between the tax authority and certain large taxpayers (those with annual turnover of €10 billion or more). This voluntary regime allows for a continuous exchange of information and is intended to reduce tax litigation. For example, the new system allows taxpayers to reach an agreement with the tax authorities as to potential tax risks prior to the submission of the tax return. It also provides an expedited advance ruling request process.


Read a September 2015 report [PDF 236 KB] prepared by the KPMG member firm in Italy: Delegation law for the reform of the Italian tax system: Implementing decree on “certainty of law rules”

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in 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 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Request for proposal



KPMG's new digital platform

KPMG International has created a state of the art digital platform that enhances your experience, optimized to discover new and related content.