Italy: Implemented Ministry of Economy and Finance Decree 1 Implementing provisions relating to the national minimum tax

On 9 July 2024, the Ministry of Economy and Finance’s Decree to implement the Qualified Domestic Minimum Top-up Tax (QDMTT), as mandated by Legislative Decree No. 209 of 27 December 2023 on international taxation, entered into force. The Decree regulates Italian entities in multinational enterprise groups or large-scale domestic groups with annual revenues of EUR 750 million or more and introduces a Qualified Domestic Minimum Top-Up Tax (QDMTT) if the jurisdictional effective tax rate is below 15%. The QDMTT is calculated on a jurisdictional basis, with separate calculations for certain entities such as joint ventures, minority-owned entities, investment entities, insurance investment entities, and stateless entities. The national minimum tax applies from the financial years starting from 31 December 2023.