April 23, 2014

Italy Launches a Cooperative Compliance Programme for Large Business Taxpayers

The Italian Revenue Agency is calling for applications to take part in a pilot project aimed at identifying a new framework of relationships between large business taxpayers and the Tax Administration.  The project follows the recently issued Organisation for Economic Co-operation and Development report “Co-operative Compliance: A Framework – From Enhanced Relationships to Co-operative Compliance”.

The new framework will envisage a commitment for taxpayers to adopt compliant behaviors based on transparency and disclosure in dealing with the Tax Administration.  In exchange for a higher level of transparency, the Agency will have to be prepared to meet taxpayers’ needs and to resolve relevant issues in a timely and effective manner.  In brief, the underlying purpose of this new model of relationships is to implement an ex-ante rather than the traditional ex-post approach to tax controls, with related benefits in terms of taxpayers’ compliance and of providing certainty and predictability in advance.

Large business taxpayers interested in filing the application may find all necessary information on the Revenue Agency's website. The deadline for applications is 31 July 2013.

© 2014 McDermott Will & Emery

About the Author


Mario Martinelli is a partner in the law firm of McDermott Will & Emery Studio Legale Associato, based in its Rome office.  He focuses his practice on advising medium and large corporations, both Italian and non-Italian resident, on virtually all aspects of Italian corporate tax law.  He advises corporate clients in both their ordinary and extra-ordinary activity, including tax planning for Italian and international restructurings and M&A, providing opinions on a wide range of tax matters covering corporate income tax, VAT, and other indirect and municipal taxes...

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