Where is your tax residence?

Your country of residence determines which CFC rules apply to your situation.

CFC Rules · Italy

Art. 167 TUIR: the Italian CFC rules apply where a resident party controls (directly or indirectly) a foreign entity subject to an effective tax rate below 50% of the Italian one (i.e. < 12% effective vs 24% IRES).

Control threshold: 50%

Domestic rate: 24%

Passive income threshold: 33.33%

Reference: Art. 167 TUIR, as amended by Legislative Decree 142/2018 (ATAD transposition)