Italy: “Fast-track” advance tax ruling process | KPMG | GLOBAL

Italy: “Fast-track” advance tax ruling process

Italy: “Fast-track” advance tax ruling process

A June 2016 decree, issued by the Ministry of Economy and Finance, implements a “fast-track” advance tax ruling program that aims at enhanced taxpayer certainty in dealings with the tax authority.


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The “cooperative compliance regime” (regime di adempimento collabrativo) was initiated in 2015, but was only effective on the publication of implementing provisions. An April 2016 “statement of practice” (no. 54237) introduced implementing measures and provided guidance about the appropriate form to be filed under the regime. This was followed by the June 2016 decree establishing the fast-track advance ruling application process.

Fast-track ruling process

Eligible taxpayers may apply for a fast-track ruling from the tax authorities when there is uncertainty about a tax issue or what is the appropriate approach to the tax treatment of a specific issue. Under the fast-track program, the tax agency must provide a written answer within 45 days of receipt of the application (instead of the 90-day to 120-day period for a standard tax ruling). The decree sets forth information concerning:

  • The subject of the tax ruling application
  • The application deadline
  • Details that must be included in the application
  • Items that will result in rejection of the application
  • How and when the tax agency must answer the application
  • The effects of the tax agency’s answer


Read a July 2016 report [PDF 218 KB] prepared by the KPMG member firm in Italy: Implementation of the new cooperative compliance regime

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