Resumen de Deemed Italian tax residence for foreign holding companies
This note considers the new Italian anti-avoidance rule introduced to counter foreign entities that have no real tax residence abroad. In particular, details are provided of the application of the new anti-avoidance rule, its primary effects, disproving the relevant assumption, compatibility with the EC Treaty and tax treaties, the implications regarding the Italian controlled foreign company legislation, and the entry into force and consequences of the legislation.
