On 12 January 2024, Italy published the Legislative Decree no. 1/2024 in the Official Gazette. The Decree details the simplification and rationalization of certain tax rules, including introducing a new tax calendar.

From 2 May 2024, taxpayers must submit their income tax return within nine months after the end of the financial year instead of the previous 11 months. As a result, calendar-year taxpayers will need to electronically file their 2023 tax return by 30 September 2024.

The new guidelines will directly impact the transfer pricing compliance. For penalty protection purposes, transfer pricing documentation should be prepared before filing the income tax return. Additionally, the transfer pricing documentation needs to be authenticated with a digital signature by the legal representative of the Italian entity and time-stamped digitally prior to filing the income tax return.