Italy’s Ministry of Finance issued a decree for implementing Pillar 2 global minimum tax reporting obligations and the EU DAC9 Directive, aligned with OECD guidance.
Italy’s Deputy Minister of Economy and Finance has 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.
This decree incorporates guidance from recent OECD publications released in January 2025, including “Tax Challenges Arising from the Digitalisation of the Economy – Administrative Guidance on Article 8.1.4 and 8.1.5 of the Global Anti-Base Erosion Model Rules” and “Tax Challenges Arising from the Digitalisation of the Economy – GloBE Information Return.”
Additionally, it enacts provisions from Council Directive (EU) 2025/872, which updates Directive 2011/16/EU (DAC 9) to facilitate the automatic exchange of information on Relevant Communications (or GIR) among EU Member States.
Furthermore, it addresses transitional simplification measures, specific deadlines (fifteenth or eighteenth month after the end of the fiscal year), and provisions for the exchange of information and collaboration on corrections between competent tax authorities to ensure compliance with the new global minimum tax regime.
The model form (Comunicazione Rilevante) must be submitted within 15 months after the fiscal year ends, extended to 18 months for the first year, and the Decree takes effect upon its publication in the Official Gazette.
Earlier, Italy’s Ministry of Economy and Finance issued the 20 December 2024 Ministerial Decree, published in the Official Gazette on 30 December 2024, detailing rules for the top-up tax and incorporating the Minimum Taxation Directive (2022/2523) into national law under Legislative Decree No. 209/2023.
