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Criteria for selecting MNE taxpayers for audits

The Italian tax authority issued Circular No. 21/2022 (20 June 2022) clarifying the criteria for selecting taxpayers for tax audits.

According to the circular, large multinational entity (MNE) taxpayers—companies with gross receipts of more than €100 million—will be selected for audit based on:

  • Transparency, with the tax authority focusing mainly on taxpayers that have not applied for rulings or advance pricing agreements (APAs) and that have not implemented an agreement under the cooperative compliance program

Source KPMG

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