Reshaping Italy's Foreign Tax Credit Regime

The Italian foreign tax credit regime will be amended as a result of Legislative Decree N. 147 of 2015, which is intended to eliminate discrimination and inconsistency. Those changes should also make the regime consistent with recent FTC guidance (Circular Letter N. 9 of 2015). The author examines interactions between the decree and the circular letter and discusses action 2 of the OECD’s base erosion and profit-shifting report. He argues that the changes resulting from the decree will likely produce little certainty and many questions.