The impact of the Swiss participation deduction on the Italian CFC regime

The article examines the impact of the Swiss participation reduction on the Italian CFC regime, focusing on the comparison between the foreign effective tax rate and the Italian domestic virtual tax rate. Although technically different from the Italian participation exemption, the Swiss regime may, in principle, qualify as fiscally equivalent where participation-related costs are fully neutralised for tax purposes. The assessment nevertheless requires a case-by-case analysis of the cost structure, the type of holding company and the composition of its income.

Author

IPG, Cristiano Lenti

Activity area

Tax Law

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IPG Journal

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IPG Journal