Italy: Implementing guidance, new tax ruling system | KPMG | GLOBAL

Italy: Implementing guidance, new tax ruling system for substantial investments

Italy: Implementing guidance, new tax ruling system

A ministerial decree and guidance from the Italian tax agency set forth the processes and procedures for implementing a new version of a tax ruling system for enterprises that intend to make “substantial investments” in Italy (investments of not less than €30 million).


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The tax ruling regime was introduced in 2015 by legislative decree (no. 147/2015). The 2015 legislative decree stipulated that actual implementation of the new tax ruling process would be completed by administrative guidance, and that the effective date for the new tax ruling system would be the date when the tax agency would issue its statement of practice.

The tax agency published a statement of practice (no. 77220) on 20 May 2016, and then subsequently issued Circular no. 25 (1 June 2016) providing clarifications for the tax ruling system.

The guidance together establishes:

  • What entities are eligible for the tax ruling procedure
  • The application process
  • The effects of a tax ruling that is granted to a taxpayer


Read a June 2016 report [PDF 118 KB] prepared by the KPMG member firm in Italy: Measures implementing the new tax ruling for substantial investments

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