Step 1 of 5
Residence
Where is your tax residence?
Your country of residence determines which CFC rules apply to your situation.
CFC Rules · ItalyArt. 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).
Reference: Art. 167 TUIR, as amended by Legislative Decree 142/2018 (ATAD transposition)
CFC Rules Check
Check whether CFC rules apply to your foreign company and what the tax impact would be.
How this calculator works
Use the free calculator for an initial assessment based on the information you enter. Results are indicative: residence, treaties, income type and local rules may change the outcome.
Calculation data is stored only when you choose to save the result and complete the required form.
Tax version and sources
Rules reviewed on September 4, 2026
Engine 2.1.0 · Rules CFC-2026.09
Tax period: 2026
Scope: GLOBAL
Rules are within the scheduled review date.
Official sources
Change history
- 2026-09-04 · v2.1.0 · Rules and sources reviewed
- 2026-09-04 · v2.0.0 · Calculation model corrections
- 2026-01-01 · v1.0.0 · Initial engine version