Global Daily Tax News, Italy Gazettes Decree On DMTT Implementation, (Jul 15, 2024)

Italian authorities have recently published a Decree in the Official Gazette to clarify matters relating to the imposition of the nation's domestic minimum top-up tax.

The top-up tax applies in Italy where an entity within a large multinational group or domestic entity faces a tax on its profits of less than 15 percent, where the group's combined annual turnover is at least EUR750m in two of the last four financial years.

The Decree includes clarifications on the operation of domestic minimum top-up taxes following the July 2023 release of new administrative guidance, including on Safe Harbors provided under the Global Anti-Base Erosion (GloBE) Rules.

The Decree specifies the scope of the domestic minimum top-up tax, tax liability calculation rules, clarifies currency-related rules, and confirms that entities within a group are jointly and severally liable for the domestic minimum top-up tax.

Italy's domestic minimum tax applies to financial years starting from December 31, 2023.