The Italian Revenue Agency published three new tax codes to allow companies to voluntarily correct information and reporting failures under the Global Minimum Tax regime, with penalties ranging from EUR 250 to EUR 100,000 depending on the violation type.
The Italian Revenue Agency announced, on 23 July 2026, that it has introduced new tax codes for paying penalties through the F24 form for voluntary disclosure of violations relating to the Global Minimum Tax’s information and reporting obligations under Legislative Decree No. 209/2023.
Resolution No. 27 of 23 July 2026 implements this final piece of Legislative Decree No. 209/2023, letting multinational and large domestic groups correct non-compliance under the ravvedimento mechanism.
The announcement follows Resolution No. 63/E of 10 November 2025, which had established codes for the underlying Global Minimum Tax payments themselves—the Income Inclusion Rule (IIR), Undertaxed Profits Rule (UTPR), and Qualified Domestic Minimum Top-up Tax (QDMTT). The new codes now handle penalties for voluntary corrections of violations under Article 51 (information obligations) and Article 53 (reporting obligations) of the decree.
Three codes for three violation types
The new tax codes, used in the F24 payment form’s Treasury section, are:
- 2735: penalties for missing relevant communications under Article 51
- 2736: penalties for missed notification obligations under Article 51
- 2737: late-filed annual minimum tax returns under Article 53
Companies filing the F24 must enter the applicable code in the Treasury section, specify the payment amount in the “amounts paid” column, and note the relevant tax year in YYYY format. This allows operators to regularise failures without waiting for the Revenue Agency to assess them.
The penalty structure and what triggers it
Article 51 of Decree 209/2023 requires Italian-based companies and transparent entities to submit mandatory communications and notifications within statutory deadlines.
The penalties are graduated by severity: failing to submit entirely or delaying more than three months brings a EUR 100,000 fine; delays under three months or incomplete/incorrect information cost EUR 10,000 to EUR 50,000. A single annual ceiling of EUR 1 million applies across all group companies in Italy. Notification-only violations carry lower penalties of EUR 250 to EUR 2,000.
Article 53 covers the annual declaration of supplementary minimum tax, UTPR, and national minimum tax, filed alongside the relevant communications. Late filings of this declaration can also be corrected through the voluntary disclosure mechanism.
Three-year grace period with reduced penalties
The law includes a transitional regime for the first three financial years: information obligation penalties won’t be imposed except in cases of willful misconduct or gross negligence.
For information penalties that do apply, the amounts are reduced by 50%. This breathing room gives multinational and large national groups time to build compliance infrastructure around the new regime’s technical requirements.
Earlier, the Italian Revenue Agency published a new FAQ on the Pillar Two GMT on 17 July 2026, expanding on the guidance first issued on 29 May 2026.
