On 2 September 2015, Italy's Legislative Decree No. 128 entered into force. The Decree introduces a new general anti-avoidance rule (GAAR) in the Taxpayer Bill of Rights, amends the statute of limitation rules for tax crimes, and introduces a new cooperative compliance program.

GAAR

Under the new GAAR, an abuse of law exists when one or more transactions lacks any economic substance and, eve…