In this note, the authors discuss the decision of the Italian Supreme Court in Case no. 25281, wherein it was held that the Italian CFC rules are consistent with EU law and with tax treaties patterned after the OECD Model.
In this note, the authors discuss the decision of the Italian Supreme Court in Case no. 25281, wherein it was held that the Italian CFC rules are consistent with EU law and with tax treaties patterned after the OECD Model.