Italy’s Cooperative Compliance Regime Broadened in Scope under 2023 Tax Reform Law

Abstract

In this note, the author outlines recent amendments to the Cooperative Compliance Regime under the 2023 Tax Reform Law. The Cooperative Compliance Regime was first introduced in 2015 for the purpose of encouraging continuous dialogue between large taxpayers and the Italian tax authorities in order to resolve potential tax disputes in advance and obtain tax certainty. To incentivize taxpayers to access the Regime, the Tax Reform Law significantly improves the Cooperative Compliance Regime mainly by broadening the range of taxpayers eligible to access it and introducing further benefits.