Significant tax measures have been approved as part of the announced tax reform.BEPS Pillar Two measures have been implemented as well as changes to domestic CFC rules for coordination with the global minimum tax provisions.Other changes include a penalty protection regime for ATAD 2 hybrid mismatches, a business reshoring exemption and the review of tax residence rules.Executive summaryOn 19 December, the Italian government has approved significant measures as a first phase of the upcoming comprehensive tax reform (International Tax Decree).1 In addition to the announced Pillar Two rules and other provisions,2 a penalty protection regime has been introduced with respect...