Public consultation for a new circular on interpretative guidelines

Deadline: 15 September 2022

After more than six years from the introduction of the Advance Tax Ruling on new investments (established by Article 2 of Legislative Decree No. 147 of September 14, 2015, and implemented with the Decree of the Minister of Economy and Finance April 29, 2016 hereinafter, “Implementing Decree”), the Italian Revenue Agency is drafting new administrative guidance better clarifying the process of this important tool.

The first guidelines on advance tax ruling on new investments (hereinafter, "Advance Tax Ruling") have been provided with the  Circular No. 25/E of June 1st, 2016 (hereafter, "Circular"), with positive response from large investors, being an attractive tool ensure advance tax certainty while still planning or considering the investments.

With the launch of this public consultation, the Italian Revenue Agency consults with interested parties to obtain input on relevant areas or on issues impeding the submission of applications.

In providing replies to the questions posed in the consultation document, please specify whether the proposed solutions can be implemented through interpretation (and, if so, please indicate the legislative references, case law or practices useful for such an interpretation) or shall require a specific legislative amendment.

Interested parties are invited to send by email written comments (in Word or other editable format) no later than 15 September 2022, to

Comments received and the name of the contributors will be published in the specific section of the institutional website of the Italian Revenue Agency, unless specifically requested not to proceed with their publication.