Italy Gazettes Decree Implementing Amendments Under DAC8 on Administrative Cooperation in Taxation

December 26, 2025, 5:00 AM UTC

The Italian Official Gazette Dec. 22 published Legislative Decree No. 194, implementing requirements under Directive 2011/16/EU on administrative cooperation in taxation, last amended by Directive 2023/2226/EU (DAC8). The decree includes measures: 1) clarifying that advance cross-border rulings for individuals are reportable only if issued, amended, or renewed after Jan. 1, 2026, with transaction values exceeding 1.5 million euros (US$1.8 million); 2) requiring inclusion of Tax Identification Numbers (TINs) of specified individuals and entities in information exchanges regarding withholding taxes, advance cross-border rulings, and country-by-country (CbC) reports; 3) requiring intermediaries to notify clients of their obligation to report cross-border arrangements; 4) ...

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