The Italian Revenue Agency (IRA) has announced the publication of Circular No. 18/E of 27 December 2021, which provides 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. This includes detailed guidance regarding the scope of the CFC regulations, the control requirement, the level of taxation requirement, the determination, allocation, and taxation of…