Italy's Legislative Decree Introducing New GAAR and Statute of Limitations Changes has Entered into Force

On 2 September 2015, Italy's Legislative Decree No. 128 entered into force. The Decree introduces a new general anti-avoidance rule (GAAR) in the Taxpayer Bill of Rights, amends the statute of limitation rules for tax crimes, and introduces a new cooperative compliance program.

GAAR

Under the new GAAR, an abuse of law exists when one or more transactions lacks any economic substance and, even if formally in compliance with tax laws, are aimed at obtaining undue tax advantages. Such tax adv…