On 11 September 2023, the Italian Ministry of Economy and Finance released a draft law for the implementation of the Global Minimum Tax rule in accordance with EU Council Directive 2022/2523 of 14 December 2022. The draft law is currently subject to a public consultation and the deadline for comments is 1 October 2023.

According to the Government’s explanatory statement, the draft law follows the EU Council Directive No. 2022/2523. This directive is designed to enact the Organisation for Economic Co-operation and Development (OECD) Pillar Two rules within the European Union. The Draft Law includes the under-taxed profits rule (UTPR), income inclusion rule (IIR), and the Qualified Domestic Minimum Top-Up Tax (QDMTT).

The IIR and QDMTT will apply from the financial year beginning on or after 31 December 2023 and UTPR will apply from the financial year beginning on or after 31 December 2024.