Ruling on the application of the Italian CFC rules to a Maltese international trading company

Journal
Russo, R. (Raffaele)
European Taxation 2006 (Volume 46), No. 3
PriceUSD 45

Details and comments are provided regarding a recent Italian ruling on the application of the Italian controlled foreign company (CFC) rules to a Maltese International Trading Company and the tax treatment of the imputation credit and the refund of the corporate income tax granted by Malta to an Italian resident shareholder receiving dividends from a Maltese company.