Italy: Regulations implementing tax dispute resolution mechanisms and MAP processes

Italy: Regulations implementing tax dispute resolution

The Italian tax authority on 16 December 2020 issued regulations to implement new tax dispute resolution mechanisms—and mutual agreement procedure (MAP) processes—following the transposition of Directive (EU) 2017/1852 into Italian law by means of Legislative Decree no. 49/2020.


The implementing regulations include:

  • Measures to allow taxpayers to contact the tax authorities in Italy to discuss the case in advance of filing the MAP request
  • A template of the MAP request to be filed with the tax authorities, if filed in the Italian language (if the MAP request is filed in another language, a certified Italian translation must be attached)
  • Rules for the electronic or paper submissions of MAP requests
  • A list of documents to be attached to the MAP request (such as a copy of the notice of assessment and a copy of the tax audit)
  • The procedures and timeframe to be followed by the taxpayer and the tax authorities under the MAP procedures
  • Measures concerning the involvement of the central and local tax offices in charge of implementing the MAP outcome

Read a December 2020 report [PDF 149 KB] prepared by the KPMG member firm in Italy

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