Calendar-year taxpayers now have until 31 October 2025 to finalise documentation for the years 2020 through 2024.

Italy’s Ministry of Economy and Finance has issued Decree Law No. 84 on 17 June 2025, extending the deadline for taxpayers to submit penalty-protection documentation concerning hybrid mismatches.

Law Decree No. 84 was published in the Official Gazette on 17 June 2025 and took effect on 18 June 2025.

The hybrid mismatch rules, introduced by Decree No. 142 of 2018, implement the EU Anti-Tax Avoidance Directive (ATAD).

Taxpayers originally had until 30 June 2025 to prepare documentation for fiscal years 2020-2022, and 31 October 2025, for fiscal years 2023-2024.

The new deadline gives calendar-year taxpayers until 31 October 2025 to complete documentation for 2020-2024. This extends the previous June deadline for fiscal years 2020-2022.

Earlier, Italy’s Ministry of Economy and Finance published the Decree of 6 December 2024 outlining the penalty relief rules for violations of hybrid mismatch rules.