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Articoli Correlati: Controlled Foreign Company - subsidiary headquarter - transfer

With the reply to ruling no. 694 of 2021, the Italian Revenue Agency specified that the transfer of the corporate headquarters of a company controlled by subjects resident in Italy from Luxembourg to Switzerland must be considered as a change in the company’s tax regime. Furthermore, it specified that the exit tax does not apply, since there is no transfer of headquarters outside the Italian territory, while it is necessary to carefully check whether, in the foreign country of destination, the CFC continues to integrate the conditions of application of art. 167 TUIR, in the particular case in which the foreign subsidiary is subject to a different tax regime or level of taxation.