Pillar 2 and CFC: overlapping hypotheses and priority rules

Giovanni Rolle and Francesco Scarfone in an article published in Corriere Tributario no. 6/2023 focus on the first interpretative issues relating to the rules soon to be introduced on the minimum taxation of multinational groups (Pillar 2), in the light of the experience gained in the application of the discipline of controlled foreign companies (CFCs), as well as the future coexistence of the two regulatory frameworks.