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Italian Decree Sets Out Requirements for Penalty Relief in Relation to Hybrid Mismatch Rules

12 December 2024

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Approved Changes

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Italy

Italy's Ministry of Economy and Finance has published the Decree of 6 December 2024 on hybrid mismatches. The Decree provides the rules for the penalty relief provided by Legislative Decree No. 209 of 27 December 2023 in relation to violations of Italy's hybrid mismatch rules. The hybrid mismatch rules were introduced as part of Decree No. 142 of 2018, which transposed the measures of the EU Anti-Tax Avoidance Directive (ATAD). The relief is subject to the condition that certain documentation is prepared and submitted to the tax authority upon request. Key points of the Decree of 6 December 2024 include:...