Italy: Implementing decree, CbC reporting rules | KPMG Global
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Italy: Implementing decree, country-by-country reporting rules

Italy: Implementing decree, CbC reporting rules

A ministerial decree, published in the official gazette on 8 March 2017, implements the rules of Law no. 208/2015 with respect to country-by-country (CbC) reporting in Italy. The CbC reporting applies for FY 2016.


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The decree sets forth provisions addressing:

  • Which entities are required to file CbC reports—generally, each ultimate parent entity of a multinational group that is a resident of Italy for tax purposes and each “surrogate parent entity” that is a resident of a country that has not implemented CbC rules, does not have a competent authority agreement, or does not exchange information from CbC reports, or each “constituent entity”
  • Details of information to be included in the CbC report—e.g., amount of revenue, profit (loss) before income tax, income taxes paid, stated capital, accumulated earnings, number of employees, tangible assets, and the identity of each “constituent entity” of the group
  • Deadlines for filing CbC reports—for FY 2016, within the due date for filing annual corporate income tax returns (nine months of the year-end) and then within 12 months from the end of the year to which the report relates

The Italian tax authorities will exchange CbC reporting information with other tax authorities within 15 months of the year at issue (except for FY 2016, which will apply 30 June 2018 or 18 months after the year-end).


Read a March 2017 report [PDF 166 KB] prepared by the KPMG member firm in Italy

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