The Circular provides additional clarifications regarding, among others, intermediaries; tax advantage and the main benefit test; timing for communication; penalties; reporting items; and hallmarks.Understanding these provisions is essential to ensuring proper reporting of cross-border arrangements under Italy’s domestic law.Executive summaryThe Italian Tax Authority published, in May 2022, the Ministerial Circular No. 12E/2022 (the Circular) on the regulation of reportable cross-border arrangements under Legislative Decree No. 100, of 30 July 2020, which transposed the European Union (EU) Directive 2018/822 of the Council of the EU (DAC6) followed by the Decree of 17 November 2020.The Circular provides additional clarifications on different matters,...