Clifford Chance
New CFC legislation: the Italian tax authorities publish their interpretation
4 January 2011
The Italian tax authorities have finally published the long-awaited guidelines on
the new Italian CFC legislation (Circular No. 51/E of 6 October 2010).
The new CFC legislation is described in a previous briefing, available at the following link: http://www.cliffordchance.com/publicationviews/publications/2009/08/impact_of_the_amendmenttothecfclegislationo.html
This briefing is focused on the tax authorities' interpretation of the key changes
in the CFC legislation.
