Italy has published Decree-Law No. 84 of 17 June 2025 in the Official Gazette, which entered into force on 18 June 2025 and contains various "urgent provisions on tax matters". Some of the key provisions concern Italy's CFC rules, including amendments to the 15% effective tax rate option for determining whether CFC income is included (imputed) in taxable income. In connection with Italy's implementation of the Pillar 2 global minimum tax, a new effective tax rate (ETR) test was introduced ba…