Italy rejects restated comparatives for the Pillar Two revenue test

An accounting change did not reset the scope test

The group exceeded the €750 million revenue threshold in 2022 and 2023. On adopting OIC 34, it presented meal-voucher agency revenue net of amounts paid to participating merchants and restated its 2023 comparative figures below the threshold. The Agency held that those comparatives, prepared under OIC 29, did not replace the revenue in the originally approved 2023 consolidated financial statements for the 2024 test.^[1]

Practical implications

Groups near the threshold should retain the originally approved accounts for each lookback year and document separately any later comparative restatement. A lower figure in the latest comparative column should not automatically overwrite the historical scope assessment. Being within scope does not itself establish that top-up tax is payable: the tax calculation, relief conditions and reporting position still require separate assessment.^[1]

Keep the conclusion specific

This is an Italian interpretation concerning OIC 34 adoption and comparative restatement. The Agency did not validate the group’s accounting treatment or quantify its tax liability. It should not be treated as a universal ruling on error corrections, formally reissued accounts or other countries’ rules.^[1]