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Italy’s CFC Regime: Wholly Artificial Arrangements

Autore : Piergiorgio Valente

In Italy the subject of controlled foreign corporations is extremely topical. The Italian Revenue Office issued Circular 51/E of October 6, 2010 (the circular), which clarified the first significant amendments introduced by article 13 of Decree-Law 78 of July 1, 2009 (the decree), on CFCs. An especially innovative change in the decree affects the scope of the CFC rules. The rules have been extended to controlled entities residing in countries or territories that are not blacklisted, whenever the entities may be qualified as ‘‘wholly artificial arrangements’’.

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