Pillar Two in Italy
Italy has implemented OECD Pillar Two through Decreto Legislativo 27 dicembre 2023, n. 209. Each applies to fiscal years beginning on or after the respective date: the IIR from 2023-12-31, the QDMTT from 2023-12-31, the UTPR from 2024-12-31.
Implementation Timeline
Each rule applies to fiscal years beginning on or after the date shown.
Quick reference
| Rule | Effective date | Status |
|---|---|---|
| IIR — Income Inclusion Rule | Fiscal years beginning on or after 2023-12-31 | In force OECD qualified |
| UTPR — Undertaxed Profits Rule | Fiscal years beginning on or after 2024-12-31 | In force OECD review pending |
| QDMTT — Qualified Domestic Minimum Top-up Tax | Fiscal years beginning on or after 2023-12-31 | In force OECD qualified |
| QDMTT Safe Harbour | Available alongside the QDMTT | Case-by-case |
Implementing legislation
- Decreto Legislativo 27 dicembre 2023, n. 209 — Attuazione della riforma fiscale in materia di fiscalita' internazionale
- IIR·QDMTT 시행 — 2023-12-31 from fiscal years beginning on or after
- UTPR — 동 법령 후속 amendment으로 2024-12-31 in force from fiscal years beginning on or after the date shown
Practical implications
MNE groups parented in Italy are subject to the IIR for fiscal years beginning on or after 2023-12-31. Where a subsidiary's jurisdictional effective tax rate (ETR) falls below 15%, top-up tax is computed and paid in Italy (as the jurisdiction of the parent entities), and the group must also file the GloBE Information Return (GIR).
MNE groups with constituent entities in Italy are subject to Italy's QDMTT for fiscal years beginning on or after 2023-12-31. Where the conditions of the QDMTT Safe Harbour are met, the IIR/UTPR computation at the parent jurisdictions may be exempted, reducing the burden of dual computation.
Recent legislative developments
- 2024 ~ 현재: 후속 in force 가이드 and OECD 행정지침 반영 amendment
- 2023-12-27: Decreto Legislativo n. 209 promulgated — IIR·QDMTT in force
Related terms
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- OECD Inclusive Framework — Updated Central Record for Purposes of the Global Minimum Tax, approved 2026-05-11 (current as at 2026-05-01). OECD Global Minimum Tax
- Agenzia delle Entrate (Italy Tax Authority) — Pillar Two guidance. www.agenziaentrate.gov.it
- Normattiva — Italy official legislation database. www.normattiva.it
Disclaimer
This page is reference information prepared as of 2026-05-28 by synthesising the primary sources listed above, and is not legal or tax advice. Before applying any of this material in practice, please:
- Verify the latest legislation, administrative guidance, and tax authority notices
- Obtain review by a qualified Pillar Two specialist
- Reassess applicability against the specific facts and circumstances of the group
Translation note. The authoritative version of this page is the Korean original (국가별 현황 › 이탈리아). This English version is provided for accessibility and may not capture every nuance of the original sources. Where precision matters, please refer to the Korean original or to the source legislation in its original language.