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Italy Issues Circular Providing Further Clarification on Specific Issues for DAC6 Reporting — Orbitax Tax News & Alerts

The Italian Revenue Agency has issued Circular No. 12/E of 13 May 2022, which provides further clarification on the application of the DAC6 reporting requirements for cross-border arrangements as introduced by Legislative Decree No. 100 of 30 July 2020 and the Ministerial Decree of 17 November 2020. Circular No. 12/E of 13 May 2022 expands upon the guidance first provided by Circular No. 2/E of 10 February 2021. In particular, Circular No. 12/E provides further clarifications on issues raised in the context of the consultation held on the initial circular that, due to their specific nature, were not covered in the initial circular or require additional clarification. This includes specific issues in relation to certain intermediaries, specific operations, verification and application of the tax reduction criteria and main benefits test, the terms of submission, sanctions in different cases, and the application of hallmarks in specific cases.