Ministry of Finance issued a decree on 16 October 2025, setting rules for Pillar 2 reporting and DAC9 compliance for multinational and large domestic groups.
RF Report
Italy’s Ministry of Finance (MoF) issued a decree on 16 October 2025, published in the Official Gazette on 29 October 2025, outlining obligations related to Pillar 2 reporting, including DAC9 requirements.
The decree defines key terms and sets out rules for multinational and large domestic groups in Italy regarding tax reporting and notification obligations. It establishes who must submit the relevant communication, including parent companies, designated entities, and local designated entities, and clarifies how reports are exchanged automatically with competent authorities through qualified agreements, including EU Directive 2025/872 (DAC9).
The decree also covers transitional periods, safe harbours, and simplified or exclusion regimes.
It aligns Italy’s framework with OECD Pillar 2 rules, commentary, and administrative guidance, ensuring compliance with global minimum tax requirements and proper exchange of tax information. The provisions are to be interpreted in accordance with Legislative Decree 209/2023 to maintain consistency with the international approach to global minimum taxation.
Earlier, Italy’s Deputy Minister of Economy and Finance signed a decree on 17 October 2025, outlining the implementation of disclosure requirements for the Pillar 2 global minimum tax information obligations as specified in Legislative Decree No. 209/2023.
