The 2016 budget law (Disposizioni per la formazione del bilancio annual e pluriennale dello Stato – Legge di Stabilità 2016) includes—as paragraph 145 of article 1—country-by-country (CbC) annual reporting requirements for multinational entities pursuant to the recommendations made in the OECD’s base erosion and profit shifting (BEPS) project.
Italy’s CbC reporting rules require multinational entities (MNEs) to report, by country, the amounts of gross profit, taxes paid and accrued, and other indicators of effective economic activities. The actual reporting requirements are expected to be set out in a to-be-issued implementing decree (anticipated to be issued within 90 days of the date of enactment of Italy’s budget law). The future decree is also expected to include details about the CbC due dates, filing instructions, and other procedural terms and conditions.
The CbC reporting requirements apply to the following:
The budget law provisions do not specifically state what is the first year for CbC reporting, but given the reference to the OECD recommendations, tax professionals in Italy believe that the CbC reporting would apply to FY 2016. Accordingly, MNEs would be expected to file their first CbC reports with their income tax returns for 2016 (i.e., filed on 30 September 2017)—this is similar to the Italian rules for preparation of transfer pricing documentation.
Read a December 2015 report [PDF 280 KB] prepared by the KPMG member firm in Italy: Italy starts the implementation of the BEPS action with the CbC reporting
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