The Decree implementing the ATAD directive and the new CFC tax regime

Recent Legislative Decree no. 142/2018, published in the Official Journal on 28th December 2018, implemented Directive no. 2016/1164, so-called ATAD 1 (Anti Tax Avoidance Directive), modifying and/or introducing several and heterogeneous tax measures. Among several innovations, this decree, rewriting art. 167 of the Consolidated Text of the Laws on Income Tax, has completely revised the tax…