Italy Clarifies Credit for Foreign Taxes Withheld for a CFC

Italy has published Resolution No. 112/E of 11 August 2017, which clarifies the foreign tax credit available in Italy for foreign taxes paid by a controlled foreign company (CFC). The resolution concerns an Italian parent of a Hong Kong CFC that was subject to withholding tax on income derived from Malaysia, the Philippines, and Taiwan for the provision of advisory services. According to the r…
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