Newsletter - Implementing provisions of the new cooperative compliance procedure for permanent establishments of foreign multinationals

On 16 April 2019, the Italian tax authorities (“ITA”) issued implementing provisions of the cooperative compliance procedure for permanent establishments (“PE”) introduced by Law Decree No. 50 of 24 April 2017.

Such procedure is targeted at large multinationals with permanent establishment exposure in Italy in fiscal years still open for assessment; in these situations foreign multinationals are now allowed to determine, jointly with the ITA, whether a PE in Italy exists, and, if so, the profits attributable to such PE. The benefits for the taxpayer are both in terms of administrative and criminal penalty protection.

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