04 October 2016 Italian Tax Authorities issue clarifications on white list CFC regime The Italian Tax Authorities issued a regulation (the Regulation) on September 16, providing further clarifications on the white list controlled foreign company (CFC) legislation. The scope of the CFC rules also includes companies located in a jurisdiction which is not considered to have a privileged tax regime, provided that both of the following conditions are met: (i) The actual income tax paid in the foreign jurisdiction is lower than 50% of the Italian corporate income tax that would be applicable to the company if it was resident in Italy; and (ii) More than 50% of the proceeds of the foreign subsidiary consists of passive income for CFC purposes. A Tax Alert prepared by EY's Global Tax Desk Network, and attached below, provides additional details. Document ID: 2016-1687 |
