On 22 December 2015 the Italian Parliament approved the
Stability Law for 2016, which was published in the Official Journal
of 31 December 2015.
The Stability Law has revised the relevant provisions of
Italy's tax code relating to so-called 'black lists' on
corporate taxation and Controlled Foreign Companies (CFC) rules. Of
particular note, the 'black lists' on (a) the deductibility
of costs and (b) CFCs have been abolished as of 1 January 2016.
This means that Guernsey will not be listed on any Italian
'black list' from 1 January 2016.
As from 1 January 2016, the only general criterion for the
application of Italy's CFC rules will be the low level of
corporate taxation of the CFC. A rate of 50% lower than the Italian
corporate tax rate (which is 27.5% for 2016 and will be 24% for
2017 onwards) is considered as a low level of taxation, both for
general and special regime. This will mean that the CFC provisions
will continue to apply as they will to all
