With the publication in the Italian Official Journal of Legislative Decree No. 100 of July 30, 2020 (the decree), which entered into force on August 26, 2020,1
Italy has transposed Council Directive (EU) 2018/822 of May 25, 2018 (directive on administrative cooperation, or DAC6), into its domestic law. The decree establishes rules and procedures for the mandatory automatic exchange of information on aggressive crossborder tax planning arrangements (reportable cross-border arrangements, or RCBAs) between the Italian Revenue Agency (Agenzia delle Entrate) and the competent tax administrations of other EU member states and between Italy and third countries in accordance with relevant agreements.
This article examines the new regulatory and operating structures arising from the DAC6 in Italy.
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