Current and Prospective Tax Measures to Attract Megaprojects to Italy

The paper provides an overview of Italian tax instruments that, more than others, seem to be capable of attracting megaprojects, i.e., projects that require large investments and expose operators to significant tax risks. In this perspective, the paper focuses on key mechanisms such as the coop-erative compliance regime, the transfer of economic activities to Italy (so-called “reshoring”, introduced by art. 6 of the Legislative Decree No. 209 of 27 Decem-ber 2023) and the ruling on new investments, as institutions that offer both tax advantages and a structured and “privileged” relationship with the Italian tax authorities. Taken together, these measures demonstrate Italy’s strategic approach, which is increasingly oriented towards tax regimes that create certainty in legal relation-ships, allow for more adequate management of tax risks and ultimately facilitate long-term investment in Italy.