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Italy issues 2024 Budget Law and tax reform decrees

23 January 2024

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Tax Alerts, Information Reporting, Legis...

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Italy

Italy's 2024 Budget Law has been issued together with multiple legislative decrees implementing part of the announced comprehensive tax reform.The most significant changes for corporations concern the implementation of Pillar Two provisions, the reshaping of controlled foreign corporation (CFC) rules, the introduction of a penalty protection regime for European Union Anti-Tax Avoidance Directive (ATAD 2) hybrids, an exemption regime for business onshoring, the repeal of the Notional Interest Deduction and the strengthening of the Cooperative Compliance Regime.The most significant changes for individuals include the review of income tax-residence rules and relevant amendments to the "Inbound workers regime." Executive summaryThe implementation process...