The paper identifies links between the recent reform of the Italian tax ation system, which began with the tax reform enabling law no. 111 of 9 August 2023, and megaprojects. Particular attention is paid to the effects that an ini tial evaluation suggests have been triggered for entities intending to commit to megaprojects following reform of the tax residence of legal entities, changes to the rules governing the controlled foreign company (CFC) tax regime, introduction of the global minimum tax into the Italian legal system, the anticipated applica tion of measures to incentivize reshoring and, finally, changes to the cooperative compliance regime.
Allena, M., The Reform of the Italian Tax System and Its Effect on the Implementation of Megaprojects, in Favari, E., Cantoni, F., Allena M, A. M., Borghetti, F., Di Nauta, P. (ed.), Sustaining the Future: Addressing Grand Challenges through Megaprojects - MeRIT Workshop 2024, Springer Nature Switzerland AG, Switzerland 2025: 600 75- 86. 10.1007/978-3-031-92797-3_6 [https://hdl.handle.net/10807/318937]
The Reform of the Italian Tax System and Its Effect on the Implementation of Megaprojects
Allena, Marco
2025
Abstract
The paper identifies links between the recent reform of the Italian tax ation system, which began with the tax reform enabling law no. 111 of 9 August 2023, and megaprojects. Particular attention is paid to the effects that an ini tial evaluation suggests have been triggered for entities intending to commit to megaprojects following reform of the tax residence of legal entities, changes to the rules governing the controlled foreign company (CFC) tax regime, introduction of the global minimum tax into the Italian legal system, the anticipated applica tion of measures to incentivize reshoring and, finally, changes to the cooperative compliance regime.
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