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Tag Archive for black-lists

Tax Alert (Italy) – Budget Law For 2018 Introduces Major Developments To Domestic Tax System

This is the fourth of a series of posts on the major developments introduced by Law No. 205 (enacting the Italian Budget Law for 2018),

Individual taxation – Modification of black-list criteria for CFC purposes: taxation of profits accrued and distributed in different fiscal periods and under different rules Read more

Tax Alert (Italy) – Budget Law For 2018 Introduces Major Developments To Domestic Tax System

This is the third of a series of posts on the major developments introduced by Law No. 205 (enacting the Italian Budget Law for 2018),

Corporate taxation – Partial exemption of dividends distributed by CFCs.

According to current Italian rules, profits realized by non-resident subsidiaries are deemed to exist under the CFC legislation (article 167(4) of the ITA) if the relevant nominal rate in the foreign jurisdiction (other than EU and EEA countries) is lower than 50% of the combined IRES tax (rate 24%) and IRAP tax (rate 3,9%). Read more