Italy: The fiscal authority publish a legislative decree to the CbCR

Published on February 21, 2018

Just recently the Italian Fiscal Authorities clarified some issues on the Country-by-Country Reporting (”CbCR”) which were still open despite the publication of a respective provision dated November 28 2017. One of the most actual themes is the late submission of the CbCR, since the corresponding deadline has basically expired on 9 February.

In this respect, it was clarified that a late submission by means of a so-called ”Ravvedimento” is possible. The ”Ravvedimento” does not cancel the penalties for non-delivery (between EUR 10,000 and EUR 50,000) but reduces them depending on the delay (within 30 days to EUR 1/18; between 30 and 90 days to EUR 1/9; within one year to EUR 1/8; within two years to EUR 1/7; over two years to EUR 1/6). Information was also provided on the following topics: scope and reporting period of the CbCR, sources from which the information to be entered are derived, collection criteria for permanent establishments, EUR 750 million threshold (valid date for exceeding in case of foreign currencies; management of exceptional transactions within the frame of the CbCR).