On 21 March 2016, the Italian tax authorities issued Protocol No. 42295, which includes the implementing rules for the changes in advance tax agreements for companies with international operations as introduced in Legislative Decree No. 147 in September 2015 ({News-2015-09-30/A/2- previous coverage}). Two of the main changes include the expanded scope of issues advance tax agreements can cover and new rollback provisions. Expanded Scope The scope of tax issues an advance tax agreement may cover is expanded to include: Asset bases in the case of inbound and outbound migrations; and Fair market value of costs incurred with black list entities...