The Italian Revenue Agency is consulting on a draft circular that provides clarifications regarding the regulations for controlled foreign companies (CFCs) as amended by Decree No. 142 of 29 November 2018 for the implementation of the EU Anti-Tax Avoidance Directive. This includes detailed guidance regarding the scope of the CFC regulations, the control requirement, the level of taxation of requirement, the determination, allocation, and taxation of CFC income, and other matters. In addition to the draft circular, the consultation also includes a draft provision that contains criteria for determining the effective level of taxation of CFC in a simplified manner.
The deadline for comments is 6 August 2021.