CFC Optional regime | Guidance
A document prepared by the professionals of Belluzzo International Partners outlining the key clarifications introduced by the Italian Revenue Agency’s Guidance No. 106520 of 31 March 2026 concerning the optional CFC regime under Article 167(4-ter) of the Italian Income Tax Code (TUIR).
The analysis provides a concise and practical overview of the most relevant developments, focusing on the implications for multinational groups and taxpayers with foreign participations, including the redefinition of the optional regime, the treatment of dividends and related compliance aspects.
Read the full document below.
