The new CFC discipline
This paper analyzes the changes made by Article 13 of Legislative Decree 78/2009, converted into Law 102 of 2009, to the discipline of Controlled Foreing Companies, hereinafter "CFC". The Revenue Agency in circular no. 51 / E of 6 October 2010, hereinafter Circular, provides an updated framework of the regulations on the subject, also focusing on the matter of profits "coming" from countries with privileged taxation and on the rules that apply to “Black List” costs.
Therefore, the previous clarifications provided on the subject are outdated if they are in contrast or incompatible with the new instructions issued by the Revenue Agency.
Topics index
- Discipline of the CFCs
- Domestic discipline of CFCs
- Conditions of non-application
- Extension of the CFC Rule
- Taxation level congruity test
- Entry into force
- Disapplication ruling
- Black List Costs
- Scope of the standard
- Relations with the CFC Rule