Italy’s Ministry of Economy and Finance has published the Ministerial Decree of 20 December 2024 in Official Gazette No. 304 of 30 December 2024. The Decree outlines additional implementation rules for the top-up tax introduced under Legislative Decree No. 209/2023. It also brings the Minimum Taxation Directive (2022/2523) into domestic legislation

Earlier, Italy’s Council of Ministers passed the legislative decree for implementing the Pillar Two global minimum tax under Council Directive (EU) 2022/2523 of 14 December 2022 on 19 December 2023.

Italy’s Ministry of Economy and Finance also issued the Ministerial Decree of 27 December 2024, which outlines rules on handling deferred tax assets and liabilities when calculating the effective tax rate (ETR) in the transition year for the top-up tax introduced by Legislative Decree No. 209/2023.

The Ministerial Decree outlines rules aligned with the Global Anti-Base Erosion Model Rules (Pillar Two) under the Commentary and Administrative Guidance of 2 February 2023 and 17 June 2024.

The Decree also outlines rules for recognising, valuing, and handling existing deferred tax assets and liabilities when calculating the ETR during the transition year. It covers deferred tax assets from qualifying transactions between 1 December 2021 and the fiscal year before the transition year.