The tax discipline of the Controlled Foreign Companies (Cfc) was changed after the transposition into the Italian law of articles 7 and 8 of the Atad 1 directive and the consequent replacement of art. 167 of the Tuir. The picture that emerged after these important changes shows, in particular, the widening of the notion of foreign companies control and the effacement of the distinction between Cfc black list and non black list.
