Italy has published Resolution No. 112/E of 11 August 2017, which clarifies the foreign tax credit available in Italy for foreign taxes paid by a controlled foreign company (CFC). The resolution concerns an Italian parent of a Hong Kong CFC that was subject to withholding tax on income derived from Malaysia, the Philippines, and Taiwan for the provision of advisory services. According to the resolution, where the CFC rules apply, a credit is available for the parent company in Italy not only…