Consistent with our commitment to provide updated information on current tax issues, we outline below the main provisions of the newly introduced Circular E.2018/2022 in relation to Controlled Foreign Companies.
In this edition (Download the PDF, 0.22 MB)
— Conditions for application of the provisions
- Definition of Controlled Foreign Companies
Α. The participation requirement
B. The requirement that Corporate Income Tax is actually paid
C. Income requirement
— Definition of “related” companies
— Income categories
— Calculation of CFC’s taxable income
— Distribution of profits by the CFC and sale of participation in the CFC
— Tax return of Individuals
— Cases where the provisions of article 66 ITC do not apply
- Companies with substantial economic activity
- Shipping companies
