The Italian Revenue Agency has published Circular No. 29/E of 28 July 2022, which provides further clarifications regarding the regulations for controlled foreign companies (CFCs) as amended by Decree No. 142 of 29 November 2018 for the implementation of the EU Anti-Tax Avoidance Directive (ATAD). Circular No. 29/E follows Circular No. 18/E of 27 December 2021, which provides detailed guidance regarding the scope of the CFC regulations, the control requirement, the level of taxation require…