From June 22, 2024, large multinational enterprises and their branches are required to publicly disclose country-specific tax information.
This requirement stems from Legislative Decree 128/2024, which implements EU Directive 2021/2101.
The decree modifies Dlgs 139/2015 by introducing a new section that mandates income tax reporting for certain businesses.
Companies that must comply include those with net revenues exceeding 750 million euros over the last two consecutive years.
This applies to EU-based multinational parent companies, subsidiaries of non-EU parent companies, and permanent establishments with net revenues over 8.8 million euros, provided the parent company's consolidated net revenue exceeds 750 million euros.
Exemptions are granted to companies under the supervision of the Bank of Italy and those belonging to non-EU groups if similar reporting is done by the parent company.
Reports must be filed within 12 months of the fiscal year-end at the business registry and be available online.
They should be accessible in Italian or a commonly used international financial language and remain public for five years.
These transparency obligations are in addition to existing fiscal information exchange requirements under EU Directive 2011/16.
The decree allows compliance by using data from existing country-by-country reporting to avoid duplication.