Country-by-Country Reporting in Italy - Guidelines published


​published on 21 Dezember 2017


With the two provisions published on November 28 and on December 11, 2017 (respectively provisions n. 275956 and n. 288555), the Italian Fiscal Authorities provided additional guidance for the Country by Country Reporting (hereinafter also ”CbCR”) in Italy.


Italian Fiscal Authorities postponed the deadline for the transmission of the CbCR from December 31, 2017 to February 9, 2018, amongst others due to the delayed publication of the clarifications of open issues connected to the CbCR (i.e. provision of November 28, 2017).


The provisions contain guidance on:
  • the entities that have to transmit the CbCR,
  • the content,
  • the sources of data,
  • the language that has to be used,
  • the currency,
  • the administrative procedure for the transmission (including the response that the Italian Fiscal Authorities have to forward to the taxpayer once the CbCR has been transmitted), the corrections that can be made (and the respective deadlines), and
  • the use and limitations of the information sent to the Italian Fiscal Authorities through the CbCR.


As some aspects of the implementation of the CbCR are still uncertain, in case of errors, the taxpayer can amend the CbCR within 60 days after the notification of the errors by the Italian Fiscal Authorities or amend the CbCR spontaneously without any time limitation.


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Hans Röll


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