The Italian Revenue Agency has published Circular No. 2 of 10 February 2021, which clarifies the application of the DAC reporting requirements for cross-border arrangements as introduced by Legislative Decree No. 100 of 30 July 2020. The circular provides guidance on intermediaries and relevant taxpayers, the scope of reportable arrangements and the application of the hallmarks, the obligations to disclose, documentation retention obligations, and penalties. With respect to penalties, the Ci…