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International Tax In Depth - 01/2024 Legislative Decree n. 209 of 27 December 2023

Italian International Tax Reform: CFC and Pillar 2 implementation


International Tax News - Italy

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The Italian Government enacted a new Legislative Decree (Legislative Decree n. 209 of 27 December 2023) aimed at reforming certain aspects of the Italian international tax law framework to align its rules with the best international practices. The decree was published on the Italian Official Journal on 28 December 2023.


The new piece of legislation touches upon several key rules of Italian international tax law, such as the criteria to establish tax residence, certain simplifications to the controlled foreign company regime, tax incentives for the reshoring of business activities and the implementation of the so-called Pillar Two rules.


The amendments to the Italian controlled foreign companies rules are aimed at simplifying certain complex features related to the calculation of the effective tax rate of the controlled foreign companies.


Legislative Decree n. 209 of 27 December 2023
Legislative Decree n. 209 of 27 December 2023


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