On Monday, 20 May, 2024, Italy’s Ministry of Economy and Finance announced the “Decree of 20 May 2024” which states the simplified transitional regimes (safe harbours) for multinational and national groups subject to the Pillar Two global minimum tax rules.
This decree includes regulations for enforcing the transitional country-by-country reporting safe harbour and related anti-arbitrage guidance, as well as the transitional UTPR safe harbour.
The decree integrates into domestic law the regimes agreed upon by the OECD BEPS Inclusive Framework, as detailed in the Safe Harbors and Penalty Relief document published in December 2022, and the administrative guidance released in July 2023 and December 2023.
