The Italian Ministry of Economy and Finance, through its Department of Finance, has published new administrative guidelines. The document directly addresses one of the most complex bottlenecks of the OECD Pillar Two reform: the heavy administrative burden related to filing the GloBE Information Return (GIR).

The explicit goal of the new Italian practice is to alleviate tax compliance obligations for businesses by establishing a centralised filing mechanism. This system avoids fragmented fulfillment across borders, relieving local subsidiaries from the duty of submitting autonomous returns in every single country where they operate, provided that strict international transparency and cooperation requirements are met.

The centralised filing mechanism and OECD requirements

The core principle established by the guidelines concerns the option for multinational groups to delegate the transmission of the GIR to the Ultimate Parent Entity (UPE) or a designated Surrogate Parent Entity (SPE). This transmission is made solely to the tax administration of the country where such entity is resident.

However, the right to benefit from the centralised filing procedure is not automatic. The Italian guidelines clarify that the waiver from local filing obligations in Italy is strictly conditional upon three cumulative prerequisites: