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New Transfer Pricing Deadline – Italy

On January 12th Italy issued the Legislative Decree 1/2024 introducing the deadline of September 30th for the yearly tax return filing, which impact the timing for the preparation of the Transfer Pricing Documentation.

What’s new?

Following the dispositions included in the 2024 Budget Law (Law December 30th, 2023, n. 213), on January 12th Italy issued the Legislative decree 1/2024 which introduces the deadline of September 30th for the yearly tax return filing.

The Legislative Decree replaces the deadline of November 30th and re-introduce the September 30th deadline, as it was few years ago, to submit the corporate tax return, for taxpayers having a calendar year-end.

The Decree also replaces the deadline of the last day of the eleventh month following the end of the fiscal year with the last day of the ninth month to submit the corporate tax return for taxpayers which have not a calendar year. Exemption applies for fiscal year 2024 in case of taxpayers which have not a calendar year with a year-end following May 2nd, 2024. For this kind of taxpayers, the nine-month period will be applied from 2025.

Impact on Transfer Pricing

The September 30th deadline also applies for Transfer Pricing purposes.

To access to the penalty protection regime, Italian taxpayers are required to prepare, digitally sign and electronically timestamp the Transfer Pricing Documentation at the time of the submission of the corporate tax return.

Taxpayers which are not able to prepare the Transfer Pricing Documentation at the time of the submission of the corporate tax return can benefit from the penalty protection regime making use of a supplementary tax return deadline that may be filed within 90 days after the standard deadline (e.g., taxpayers with a calendar year-end can declare the availability of the compliant Transfer Pricing Documentation, properly digitally signed and electronically timestamped, until December 30th).

Key actions

To benefit from the penalty protection regime, Italian taxpayers with a calendar year-end are required to prepare the compliant Transfer Pricing Documentation (properly digitally signed and electronically timestamped) within September 30th. A supplementary tax return deadline may be filed within 90 days after September 30th for penalty protection purposes.

To get prepared to the new deadline, Italian taxpayers must plan the necessary activities required to organize the preparation of the proper Transfer Pricing Documentation.

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