Italy
A. Progress in the implementation of the minimum standard
Italy has 100 tax agreements in force as reported in its response to the Peer Review questionnaire. Two of those agreements comply with the minimum standard.
Italy signed the MLI in 2017. The agreements modified by the MLI come into compliance with the minimum standard once the provisions of the MLI take effect. Italy has not listed its agreements with Albania, Belarus, Congo, Montenegro, North Macedonia, Oman, and Panama. These agreements will therefore not, at this stage, be modified by the MLI. Albania, North Macedonia, Oman and Panama have listed their agreements with Italy under the MLI.
Italy indicated in its response to the Peer Review questionnaire that steps have been taken (other than under the MLI) to implement the minimum standard in its agreements with Brazil, Norway and Uzbekistan*.
Italy indicated in its response to the Peer Review questionnaire that the agreements with Belarus, Congo, Ecuador*, Ethiopia*, Ghana*, Kyrgyzstan*, Montenegro, Mozambique*, Syria*, Tajikistan* and Venezuela* do not give rise to material treaty-shopping concerns for Italy as they contain specific features and as Italy’s domestic anti-abuse legislation applies.
Italy is implementing the minimum standard through the inclusion of the preamble statement and the PPT.1
B. Conclusion
Albania, North Macedonia, Oman and Panama have listed their agreements with Italy under the MLI, which amount to requests to implement the minimum standard. Italy has developed a plan for the implementation of the minimum standard in its agreements with Albania, North Macedonia, Oman and Panama. Italy indicated in its response to the Peer Review questionnaire that it intends to expand its list of agreements to be covered under the MLI to include those agreements.
← 1. For its agreements listed under the MLI, Italy is implementing the preamble statement (Article 6 of the MLI) and the PPT (Article 7 of the MLI). Italy has made a reservation pursuant to Article 7(15)(b) of the MLI not to apply Article 7(1) of the MLI with respect to agreements that already contain a PPT (covering thirteen agreements).