Stricter anti-avoidance rules for tax havens

Companies not falling under any of the rules which regulate company groups and which have a controlling interest in companies based in countries with a preferential tax regime, continue to be subject to the anti-avoidance provisions for controlled foreign companies (Cfc), so that the profits of the companies abroad is attributed on a pro-rata basis to the Italian company, regardless of their effective distribution (with some exclusions). From 2004, this provision is also applicable to associated shareholdings with a system of income attribution which takes into account not only the profits actually derived by the company, but also what it could have derived through the application of specific income ratios to the business assets.