Cooperative compliance program

What is it

The cooperative compliance program is aimed to promote an enhanced cooperation between the Italian Tax Administration and taxpayers in order to increase the level of  certainty on relevant tax issues and, consequently, to prevent tax litigations.

Who can access the program

  1. Resident and non-resident entities having a permanent establishment in Italy with a total turnover or operating revenues exceeding 10 billion euros
  2. Resident and non-resident entities having a permanent establishment in Italy with a total turnover or operating revenues equal to at least 1 billion euros, which applied for the pilot project launched in 2013
  3. Entities granting execution to the opinion of the Italian Revenue Agency in response to the advance ruling on new investments, notwithstanding threshold of turnover or revenues.

In addition, resident and non-resident companies who have the requirements set out in points  n. 1) and n. 2) can, at the time of submission of the application form, ask the admission to the cooperative compliance program even for their resident and non-resident entities having a permanent establishment in Italy, performing strategic direction functions in relation to the tax control framework, regardless of the amount of turnover or revenues.

How to adhere to the program

Eligible taxpayers must file an application including fundamental information on the enterprise, with particular regard to the adopted tax control framework.

Benefits

Admission to the cooperative compliance program allows taxpayers to benefit from several advantages:

  • fast track ruling (no more than 45 days since the receipt of request or the integration of documents) regarding the application of tax provisions
  • tax penalties reduced of 50% and, in any case, applied to an amount not exceeding the minimum provided by law
  • no guarantees required to obtain refunds of direct and indirect taxes