Effective from the fiscal year starting after the fiscal year in progress to December 31, 2018 (i.e. from January 1, 2019 for calendar year companies), new Italian CFC rules were introduced by Legislative Decree n. 142/2018 which implemented in Italy the EU Anti-Tax-Avoidance Directive (so called, ATAD 1 and 2).
Controlled foreign company (CFC) rules have the effect of re-attributing the income of the controlled foreign entities to their shareholders, resident in Italy (individual, parent company, etc.). According to new art. 167 of the Presidential Decree n. 917/1986, a foreign company is qualified as CFC when at least one of the following conditions is met.