Italy published the Decree of 11 October 2024 in the Official Gazette on 23 October 2024, which addresses reducing the taxable base relevant to the global minimum tax.
Earlier, Italy’s Ministry of Economy and Finance announced the Decree of 11 October 2024, which sets out rules for applying the substance-based income exclusion (SBIE) when calculating top-up tax.
The decree takes into account the clarifications provided in the Commentary to the OECD Rules and the Administrative Guide “Tax Challenges Arising from the Digitalisation of the Economy – Administrative Guidance on the Global Anti-Base Erosion Model Rules (Pillar Two)”, approved by the Inclusive Framework on BEPS on 13 July 2023, regarding the amount of income that can be excluded from supplementary taxation because it is attributable to the performance, in a given country, of substantial economic activity.
