ITALY Law and Practice Contributed by: Giuliano Foglia, Foglia & Partners
at least EUR500 million (EUR100 million from 2028), to establish an ongoing dialogue with the competent offices of the Italian Revenue Agency, aimed at pro - viding taxpayers with facilitated instruments to obtain certainty on possible issues related to the interpreta - tion and application of tax provisions as well as eligi - bility for specific tax regimes. The most relevant facilitations consist of: • reduced term for obtaining an advance answer from the Italian Revenue Agency to ruling requests (45 days, instead of the ordinary 90 days); and • at certain conditions, no/reduced penalties in case of challenges by the Italian Revenue Agency; • under certain conditions, no criminal liability for the offence of incorrect tax return; and • reduced statute of limitation for tax audits (three years, instead of the ordinary five years).
Taxpayers adhering to the cooperative compliance regime must have an effective integrated system for identifying, measuring, managing and controlling tax risks, including those arising from the application of accounting principles (“Tax Control Framework” or “TCF”).
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