New regulations for foreign subsidiaries – the contribution of WTS R&A to the public consultation of the Revenue Agency

The contributions to the public consultation launched on July 5, 2021 by the Revenue Agency on the implementation of the rules of Controlled Foreign Companies (CFC) after the amendments of the European anti-abuse directive (“ATAD”) were published today. WTS R&A Studio Tributario participated in the consultation with observations focused on five specific points:

  1. measurement of the level of effective taxation for subsidiaries included in group taxation
  2. equivalence of holding regimes
  3. “sterilization” of temporary differences
  4. transfer of residence and tax assets of the CFC
  5. double taxation and distribution of the profits of the CFC

The full text of the contribution of WTS R&A is published, as well as those of the other participants, on this page.