On issue 6/2022 of the Rivista della Guardia di Finanza, Alberto Trabucchi, together with his colleague Stefano Grilli, analyzes in the contribution entitled “Interactions between the CFC legislation and Pillar 2 – Part I” the complex coordination of the national CFC disciplines with the rules of Pillar 2, in light of the specific provisions contained in the Model Rules issued by the OECD as part of the so-called global minimum taxation and implemented by the EU in mid-December 2022 in the Directive 2022/2523/EU. The contribution provides a first systematic framework of the coordination rules, also investigating the problematic practical aspects related to the application of the rules.
This contribution will be followed by a second intervention, aimed at investigating further profiles of complexity emerging in the application phase of the aforementioned coordination provisions.
Interazioni tra la normativa CFC e il Pillar 2 – Parte Prima_Trabucchi-Grilli