On 29 December 2022, the Italian Parliament approved the Budget Law for 2023 (the Law).The Law is generally effective from 1 January 2023 and provides for several tax measures that may be of interest to multinational enterprises (MNEs) with Italian operations, including: (i) Limited deduction of costs incurred with black-listed jurisdictions; (ii) Transition tax on undistributed profits from low-tax subsidiaries; (iii) Nonresidents’ capital gains on indirect transfers of Italian real estate; (iv) Step-up of Italian participations held by nonresident entities; (v) Permanent Establishment exemption for investment management activities; (vi) One-off energy windfall tax; and (v) Tax amnesty measures. These and...