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New cooperative compliance procedure focused on Italian permanent establishments of large multinationals
Marco Cerrato is the author of the paper on the new cooperative compliance procedure focused on Italian permanent establishments of large multinationals (published by Rivista di Diritto Tributario).
Article 1-bis of Law Decree No. 50 of 4 April 2017, converted by Law No. 96 of 21 June 2017, introduced a new cooperative compliance procedure that now allows large multinational groups to discuss and examine jointly with the Italian Revenue Agency whether they may be deemed to have a permanent establishment in Italy. This new procedure entails significant benefits for the taxpayer in relation to both administrative and criminal penalties. This new procedure was presented to the media and politically as a sort of an interim web tax aimed at compensating in part for the revenue loss that connected to digital economy. However, this is not a new tax or levy. Nor is the procedure applicable only to multinationals in the digital economy sector. This paper analyses the features of the new procedure and will also compare it with similar existing regimes (i.e. standard cooperative compliance, international tax ruling, tax settlement, regularization procedure, late filing of the omitted tax declaration, voluntary disclosure) to identify similarities and differences.