Menu della sezione Invest in Italy
- Allowance for corporate equity (Ace)
- Tax credit on research and development activities
- Patent box regime
- Super-amortization and Hyper-amortization
- Vat grouping rules
- Tax regime for new residents
- Advance tax ruling on new investments
- Advance tax ruling
- Cooperative compliance program
- Advance tax agreements for enterprises with international activities
- Flat-rate scheme
Cooperative compliance program
Cooperative Compliance
At a glance
Aim: promote an enhanced cooperation between the Italian Tax Administration and taxpayers and prevent tax litigations.
Qualifying entities:
- Resident and non-resident entities having a permanent establishment in Italy with a total turnover or operating revenues:
- exceeding 5 billion euros;
- equal to at least 1 billion euros, which applied for the pilot project launched in 2013;
- granting execution to the qualified opinion of Italian Revenue Agency, in response to the advance ruling on new investments;
- participating in Vat Group of companies yet included into the program regardless of the amount of turnover or revenues;
- resident and non-resident companies who have the requirements set out in the first point, can be admitted 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 (can be extended).
Benefits: fast track ruling regarding the application of tax provisions, tax penalties are reduced of 50% and, in any case, applied to an amount not exceeding the minimum provided by law. No guarantees required to obtain tax refunds.
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
- Resident and non-resident entities having a permanent establishment in Italy with a total turnover or operating revenues exceeding 5 billion euros (DM 30 march 2020 reduced the amount from 10 billion to 5 billion euros for fiscal years 2020 and 2021)
- 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
- 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
- Entities part of Vat Group of companies yet included into the program (DL 119/2018) regardless of the amount 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