OrbitaxCFC rules apply to Italian company with subsidiary and branch in black listed country, even if actual business activity carried on
|Approved Changes|Italy-Cyprus-United Arab Emirates
On 5 May 2008, the Italian tax authorities (ITA) issued ruling No. 187 according to which the controlled foreign corporation (CFC) rules apply to an Italian company with a subsidiary in Cyprus that carries out an actual business activity through a branch in Dubai (United Arab Emirates).
(a) Facts. An Italian company undertook a joint venture agreement with a Frenc…
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