Starting from January 1st, 2019, Italy adopted (through Legislative Decree no. 145/2018) the so-called EU "Anti-Tax Avoidance Directive" no. 2016/1164 ("ATAD 1"), as modified by the EU Directive 2017/952 ("ATAD 2"), finalized at strengthening the existing provisions against international tax avoidance behaviours. The main measures affect: (i) interests deduction; (ii) the controlled foreign companies (CFC) rule; (iii) dividends and capital gains related to black listed companies, (iv) the definition of "financial intermediaries"; (v) exit/entry taxation for tax payers moving their residence from/to Italy; and (vi) hybrids mismatches.
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