The Cooperative Compliance Regime, introduced in Italy by Legislative Decree No. 128/2015 and updated by Legislative Decree No. 221/2023, establishes a framework for proactive collaboration between taxpayers and the Italian tax authorities to prevent and resolve tax disputes. Initially targeting large taxpayers with a turnover exceeding €750 million, the regime will progressively expand its eligibility threshold to €500 million in 2026 and €100 million in 2028. Participants are required to implement and certify a robust Tax Control Framework (TCF) integrated into their corporate governance, ensuring effective tax risk management and compliance.
The regime offers significant benefits, including expedited rulings, reduced penalties, exemptions from guarantees for tax refunds, and criminal immunity for disclosed tax risks. On June 7, 2024, a Code of Conduct was published, defining mutual commitments for both taxpayers and tax authorities, focusing on transparency, ethical tax practices, and proactive dialogue. Updated provisions introduced in June 2024 aim to enhance access and strengthen legal protections, making the regime an attractive tool for businesses committed to compliant and transparent tax practices.