Italian Revenue Agency Provides New CFC Guidance

Although Italy revised its CFC legislation in 2018 (Legislative Decree 142) in order to implement the EU Anti-Tax Avoidance Directive (2006/1164), it was not until December 2021 that it provided guidance on implementation in Circular letter 18/E. This article addresses the most significant aspects of the Circular, in particular in light of comments received during the public consultation that preceded its release.