Italy: Implemented Legislative Decree No. 209 on International Taxation implementing Council Directive (EU) 2022/2523 on Global Minimum Tax

On 29 December 2023, the Legislative Decree No. 209 on International Taxation implementing Council Directive (EU) 2022/2523 on Global Minimum Tax entered into force. The Decree establishes an effective tax rate of 15% and introduces several obligations, including a Qualified Domestic Minimum Top-Up Tax (QDMTT), an Income Inclusion Rule (IIR) for parent companies of low-tax foreign entities, and an Undertaxed Profits Rule (UTPR) for Italian companies in multinational groups with low-taxed affiliates abroad. The Decree also provides for a de minimis exclusion to multinational or national group companies located in a jurisdiction where their aggregate revenues are less than EUR 10 million and their incomes are less than EUR 1 million, on average, over a three-year period.