The new provisions apply to financial statements relating to financial years beginning on or after 22 June 2024. Therefore, for companies whose financial year coincides with the calendar year, the first reporting obligation concerns the 2025 CBCR.
The CBCR Report must be filed with the Companies Register within 12 months from the end of the financial year to which the Report relates. Accordingly, for the financial year ended 31 December 2025, the filing deadline is 31 December 2026.
By Decree of the Italian Ministry of Enterprises and Made in Italy (MIMIT) dated 20 May 2026, the technical specifications required for electronic filing with the Companies Register were approved.
I. Mandatory Reporting Entities
1. The obligation applies to multinational groups that, as of the reporting date of the consolidated financial statements, have recorded consolidated revenues exceeding EUR 750,000,000 in each of the last two consecutive financial years.
2. In particular, the Report must be filed by:
a) Italian resident parent companies;
b) Italian resident standalone companies;
c) Italian subsidiaries controlled by a parent company resident in a third country (non-EU);
d) Italian branches (including permanent establishments, secondary branches or local units) of enterprises that exceed the size thresholds applicable to non-EU standalone entities with the characteristics described above, or of non-EU entities belonging to a group whose consolidated revenues exceed the above threshold and whose ultimate parent company is also established outside the EU.
3. If the parent company does not provide all information necessary to comply with the reporting obligation, the subsidiary shall nevertheless prepare, publish and make available an income tax information report containing all information available to it or otherwise obtained by it, together with a statement confirming that the parent company did not provide the required information.
II. Publication Requirements
1. Within the same deadline applicable for filing the Report (within twelve months from the end of the relevant financial year), the Report must also be published on the company’s website, ensuring free public access in either Italian or English. The document must remain publicly available for a minimum period of five consecutive years. The filing documentation submitted to the Companies Register must expressly confirm that such publication has been completed.
III. Exclusions and Exemptions
1. Not all companies belonging to multinational groups with revenues exceeding EUR 750 million are required to physically file the Report with the Italian Companies Register.
2. In particular, the following entities are excluded from the filing obligation:
a) An Italian parent company whose subsidiaries and branches are all subject exclusively to Italian tax jurisdiction;
b) An Italian standalone company whose branches are all located in Italy;
c) An Italian subsidiary controlled by a parent company established in an EU Member State. In this case, the filing obligation is fulfilled by the parent company in its EU jurisdiction;
d) An Italian branch established by an EU subsidiary belonging to a group headed by a non-EU parent company. In this case, the filing obligation rests with the EU subsidiary that established the Italian branch.
3. Certain exemptions are also available. In particular:
a) An Italian subsidiary of a parent company established outside the EU (which would otherwise be required to file);
b) An Italian branch established by a non-EU parent company or by a non-EU subsidiary (which would otherwise be required to file);
c) An Italian branch of a non-EU standalone undertaking (which would otherwise be required to file);
shall be exempt from preparing and publishing the Report if the non-EU parent company prepares an equivalent income tax information report and, provided that:
i) the equivalent report is made publicly available free of charge and in a machine-readable electronic format on both the parent company’s website and the subsidiary’s website within twelve months from the end of the relevant financial year;
ii) the equivalent report is prepared in at least one of the official languages of the European Union, provided that, where the designated subsidiary is Italian, the version published on its website is in Italian or English;
iii) the equivalent report specifies the name and registered office of the subsidiary concerned.
4. Where the non-EU parent company has designated a subsidiary or branch established in another EU Member State, no filing obligation arises in Italy. However, the directors of the Italian subsidiary must notify the Companies Register that the company is exempt because the Report has been filed in another EU Member State by another company of the same group.
IV. Structure and Content of the Report
1. The Report must be prepared in accordance with the taxonomy established by Commission Implementing Regulation (EU) 2024/2952 in the electronic Inline XBRL (iXBRL) format, with a .html or .xhtml extension, and digitally signed (with .p7m extension). Accordingly, specific software solutions are required.
2. The Report consists of five standardized sections:
Section 1 – General Information: Company name, reporting period, reporting currency (consistent with the financial statements), and indication of the accounting basis adopted (IFRS/OIC) or tax basis (DAC6/DAC4 tax reporting to the Italian Revenue Agency, where applicable).
Section 2 – Quantitative and Financial Information: Brief description of activities performed; number of full-time employees; total revenue (including related-party transactions); profit or loss before tax; accrued income tax expense for the year (excluding deferred taxes and uncertain tax provisions); income taxes actually paid on a cash basis (including withholding taxes suffered); and accumulated undistributed earnings at year-end.
The data must be reported on a disaggregated basis according to strict rules:
a) Separate disclosure is required for each EU Member State;
b) Separate disclosure is required for each jurisdiction listed in Annex I of the EU list of non-cooperative jurisdictions (the so-called “Black List”);
c) Separate disclosure is required for each jurisdiction listed in Annex II of the EU list (the so-called “Grey List”);
d) Data relating to all other jurisdictions (third countries not falling within the above categories) must be presented on an aggregated basis.
Section 3 – List of Entities: Identification of all consolidated subsidiaries established in the relevant jurisdictions.
Section 4 – Omissions: Optional section not provided for under Italian legislation and therefore not applicable to Italian reporting entities.
Section 5 – Explanatory Notes: Narrative explanation intended to clarify any significant discrepancies between accrued income taxes and taxes actually paid.
V. Penalties
1. Failure to comply with the disclosure requirements may result in the following administrative penalties:
a) Failure to file: administrative penalty ranging from EUR 10,000 to EUR 50,000;
b) Late filing: where the filing is made within 60 days after the deadline, the penalty is reduced by half (from EUR 5,000 to EUR 25,000). Filing beyond the 60-day period is treated as a complete omission;
c) Inaccurate or incomplete reporting: where the Report contains material misstatements or omits mandatory information, the administrative penalty is doubled.
We remain at your disposal should you\ require any assistance in fulfilling the above obligations.
