A robust new legislative initiative in Italy is expected to help
international companies limit tax compliance risks by boosting
cooperation with the Italian authorities.
With the Provision of the Italian Revenue Agency dated 21 March
2016, protocol. 2016/42295, the guidelines for advance agreements
for companies operating internationally, newly introduced by Art.
31-ter of Presidential Decree No. 600 of 29 September
1973, were definitively implemented.
Article 1, paragraph 1 of Legislative Decree no. 147 of 14
September 2015 (the so-called Internationalisation Decree)
rescinded the previous legislation introducing Art. 31-ter
of Presidential Decree no. 600 of 29 September 1973 with
"Advance agreements for companies operating
internationally" and defines the methodology for the
identification of the fiscal position of the taxpayer. The new
procedure enables the taxpayer to make an agreement with the
Italian Revenue Agency, in its dedicated division – the
Office of
