Italy - Amendments to the Italian Controlled Foreign Company Rules: A Witch-Hunt?
- Sebastiano Garufi
- European Taxation, 2009 (Volume 49), No 10
- 8 September 2009
This note critically reviews the recent amendments to the Italian controlled foreign company legislation, the new enlarged scope of which goes well beyond traditional low-tax jurisdictions. Although the new provisions acknowledge the case law of the European Court of Justice, there are many issues that need to be clarified, as they risk curtailing the growth of Italian groups.