On 21 September 2026, the Italian Revenue Agency (Agenzia delle Entrate) published Circular 6/E, implementing the provisions of Legislative Decree No. 221/2023. This circular fundamentally redesigns the Tax Control Framework, the system through which enterprises identify, measure, and manage their tax risk. The measure marks a significant evolution in the relationship between the State and businesses, shifting from a purely adversarial model toward a cooperative compliance paradigm. The new framework introduces enhanced obligations for taxpayers to adopt robust internal tax governance structures, aligning domestic practice with international standards such as the OECD’s guidance on cooperative compliance and the ICAP (International Compliance Assurance Programme) process.
Key Takeaways
- Mandatory Tax Control Framework Enhancement: Circular 6/E requires qualifying enterprises to formalize a comprehensive Tax Control Framework embedded within their corporate governance. This includes documented policies, risk mapping, monitoring activities, and periodic reporting to the tax administration, effectively making tax risk management a board-level responsibility.
- Collaborative Compliance as Regulatory Standard: The circular operationalizes the “adempimento collaborativo” (collaborative compliance) regime, granting admitted taxpayers benefits such as penalty protection, advance certainty on tax positions, and dedicated communication channels with the Revenue Agency. Admission is conditional on demonstrating effective tax governance and transparency.
- Integration with Legislative Decree 231/2001 Liability Models: The guidance explicitly links the Tax Control Framework to the organizational models under Legislative Decree 231/2001 (corporate administrative liability). Companies must ensure tax risk controls are integrated into their 231 Models, creating a unified compliance architecture that mitigates both tax and criminal liability exposure.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement