On 1 July 2009, the Italian Tax Administration (ITA) enacted the Anti-crisis Law Decree No. 78 (the Decree), which, amongst other measures, broadened the scope of the Italian CFC rules to beyond the mere tax haven jurisdictions. According to Art. 13 of the Decree, the Italian CFC rules apply to any jurisdiction in which the following two conditions are met:
| - | the effective taxation of the controlled foreign company … |