New law has been introduced by the Italian Revenue Agency for the execution of CbCR concerning the medium of presentation of the reports in Italy which is in the same radar with the OECD recommendations and the EU Directions. It is mainly implied on the primary Italian ultimate parent companies of multinational groups who have a consolidated revenue of fiscal year exceeding or equaling $884 million. It is furtherly implied on those Italian subsidiaries who belongs to multi-national companies whose consolidated revenue meets the previously mentioned threshold and one of the following is true.

• The ultimate parent of the group has no voluntary filling and no CbCR duties in jurisdiction of tax residence.
• No agreement is in effect for the automatic exchange of CbC reports between Italy and the jurisdiction of residence of the ultimate parent company within the 12 month deadline for reporting.
• There is systematic failure in compliance with such – existent – agreement by the said jurisdiction.

However, an Italian subsidiary can be relieved of such obligations if a foreign multinational group of a surrogate parent entity fulfill the CbCR obligations and fill their own tax jurisdiction but for it to happen, the surrogate parent entity must be a non-EU country and there must exist a CbCR obligation of the that particular country as well as an effective agreement of for automatic exchange of CbC reports between Italy and that particular country of that financial year.
The reporting entities must include a list of each resident in each jurisdiction where the group performs its activities, indicating the nature of each entity’s main activities as well as are expected to communicate within the 12 months from the last day of tax reporting year of the group.
Taxpayers must systematically use the same source of data in their CbC reports and if they use different sources of data, they must provide explanations for it and the currency that will be mentioned in the report must be of that particular entity used by them in their consolidated revenue.