As previously reported, Italy's Council of Ministers approved the legislative decree for the implementation of tax reforms regarding international taxation on 19 December 2023. This includes, among other things, the implementation of the Pillar 2 global minimum tax in accordance with Council Directive (EU) 2022/2523 of 14 December 2022. In relation to this, the legislative decree also amends the country's controlled foreign company (CFC) regime with effect from 1 January 2024. Under the current CFC regime, one of the conditions for the imputation of CFC income is that the CFC is low taxed, which is the case where the CFC...