The Italian Revenue Agency has issued the provisions for the controlled foreign company (CFC) substitute tax option introduced as part of Legislative Decree No. 209 of 27 December 2023. As previously reported, Legislative Decree No. 209 includes measures for the implementation of the Pillar 2 global minimum tax in accordance with Council Directive (EU) 2022/2523, as well as related amendments to the country's CFC regime with effect from 1 January 2024. Among other things, this includes a sim…