The Italian Revenue Agency is consulting on a draft circular that provides clarifications regarding the regulations for controlled foreign companies (CFCs) as amended by Decree No. 142 of 29 November 2018 for the implementation of the EU Anti-Tax Avoidance Directive. This includes detailed guidance regarding the scope of the CFC regulations, the control requirement, the level of taxation of requirement, the determination, allocation, and taxation of CFC income, and other matters. In addition…