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EYEY

Italian penalty protection regime for tax hybrids becomes effective

|Tax Alerts, National/Federal Taxation, Global|Italy
Italy
  • A penalty protection regime for tax-hybrid mismatches is now available after the publication of the relevant ministerial decree in the Italian Official Gazette.
  • The regime requires taxpayers to prepare qualifying documentation disclosing each covered transaction for each fiscal year. Alternatively, for imported hybrid mismatches, the penalty protection may be achieved by adopting a single internal control framework.
  • The regime is also available for past fiscal years, provided that certain deadline…

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