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Clifford Chance

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:

This briefing is focused on the tax authorities' interpretation of the key changes
in the CFC legislation.

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