Italy approves BEPS Pillar Two provisions and other significant tax changes including ATAD 2 hybrid mismatches penalty protection regime

22 December 2023|Tax Alerts, Information Reporting, Legislation & Policy, National/Federal Taxation, BEPS 2.0|Italy

Significant tax measures have been approved as part of the announced tax reform.
BEPS Pillar Two measures have been implemented as well as changes to domestic CFC rules for coordination with the global minimum tax provisions.
Other changes include a penalty protection regime for ATAD 2 hybrid mismatches, a business reshoring exemption and the review of tax residence rules.

Executive summary

On 19 December, the Italian government has approved significant measures as a first phase of the upcoming comp…

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