The Italian Cooperative Compliance Regime: Governance, Practical Perspectives and Future Developments

This article examines the Italian cooperative compliance regime and argues that Italy offers an instructive case study for the broader European debate on preventive, trust-based tax administration. After outlining the legal framework, it analyses how the regime operates in practice, highlighting issues of scalability and the gap between formal design and practical effects. It then considers how different categories of companies assess the costs and benefits of participation, showing that the regime functions as a selective governance instrument, more attractive to firms with mature internal controls. Finally, it identifies the main policy conditions for the Italian regime’s future effectiveness.