Coordination between Italy’s Anti-Hybrid Mismatch Rules and Italy’s CFC Regime Proves Complicated

Abstract

Legislative Decree no. 142/2018 implements into Italian legislation the anti-hybrid mismatch rules of ATAD 2 (2017/952), which are aimed at blocking aggressive international planning that erodes the tax base through schemes that cannot be attacked through anti-avoidance rules. This article, which takes into account recent guidelines issued by the tax authorities, focuses on coordination between the anti-hybrid mismatch rules and Italy’s CFC rules.