CFCs: interpretive and applicative doubts regarding the amendments

In Corriere Tributario (No. 8-9/2024), Giuliano Foglia and Sergio Mango analyse the new optional CFC regime introduced by Article 3 of Legislative Decree no. 209/2023 and implemented in Article 167 TUIR in paragraphs 4-ter and 4-quater. In detail, the paper focuses on some applicative aspects on which official clarifications from the Tax Authority would be welcome.