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A Ministerial Decree (dated February 25, 2025, and published March 6, 2025) introduces a global anti-base erosion (GloBE) information return (GIR) notification requirement for groups in scope of the Italian Pillar Two legislation to inform the Italian tax authorities about the identity and location of the entity submitting the GIR on behalf of other group members.

The decree also includes a notification template, requiring the following information:

• The name of the MNE group or large-scale domestic group
• The tax code of the entity submitting the notification
• Information on the contact person
• Information on the ultimate parent entity (UPE), such as the tax code, the jurisdiction of the UPE, and whether the GIR will be transmitted to the Italian Tax Authority via an exchange agreement
• Information on the designated filing entity
• Information on the designated local entity
• Relevant reporting fiscal year

The notification needs be filed no later than 15 months after the end of the fiscal year (18 months for the transitional year). The actual notification form and further details on the submission will be clarified by the revenue agency.

Read a March 2025 report prepared by the ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø’s EU Tax Centre