A penalty protection regime for tax-hybrid mismatches is now available after the publication of the relevant ministerial decree in the Italian Official Gazette.The regime requires taxpayers to prepare qualifying documentation disclosing each covered transaction for each fiscal year. Alternatively, for imported hybrid mismatches, the penalty protection may be achieved by adopting a single internal control framework.The regime is also available for past fiscal years, provided that certain deadlines are respected.Limitations may apply with reference to transactions for which the Italian tax authorities have already started audit activities.  Executive summaryOn 20 December 2024, an Italian government decree implementing the penalty protection...