The Council of State (Consiglio di Stato) issued a favourable judgment on 21 February 2006 (reported in April 2006) on the draft implementing rules, issued by the Italian Tax Authority, for the extension of the controlled foreign companies (CFC) legislation to "related entities".

Following the 2003 Italian tax reform (Legislative Decree 344 of 12 December 2003), the CFC rules were ex…

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