On 10 June 2020, the Italian Government published Legislative Decree n. 49 enacting EU Directive No. 2017/1852 regarding tax dispute resolution mechanisms and in particular disputes arising from the interpretation and application of tax treaties.
The Decree implements new rules to resolve disputes between Italy and other EU tax authorities on the interpretation and application of agreements and conventions for the avoidance of double taxation (Mutual Agreement Procedure or MAP).
The decree will apply to any request for a mutual agreement procedure (MAP) submitted from 1 July 2019 onwards, in relation to disputes about the tax treatment of income or capital earned in a fiscal year commencing on or after 1 January 2018.
