A CFC is a legal person or entity which is resident for tax purposes in another country if the following conditions are met cumulatively: a) if the taxpayer alone or jointly with the associated persons directly or indirectly holds shares, stakes, voting rights or participations in the capital exceeding fifty percent (50%) or is entitled to over fifty percent (50%) of the profit of that legal person or entity, b) if the above legal person or entity is subject to taxation in a non-cooperating state or a country with a preferential tax regime, i.e. a special regime allowing for a substantially lower taxation level than that under the general regime, c) if more than thirty percent (30%) of net income before tax realized by the legal person or entity falls into one or more certain categories defined in the very same article, d) the legal person or entity is not a company of which the main class of shares of which are traded on a regulated market.