On 21 September 2007, the Italian tax authorities issued Ruling No. 262 aiming at clarifying the applicability of the CFC regime to companies resident in a country which has a privileged tax regime and is therefore included in the "black list" (Ministerial Decree 21 November 2001, No. 429) even if their average tax rate is at least 27%.
(a) Fact. An Italian company (the Company) owns a shareholding in a company resident in a black list country, namely…