The Italian-resident taxpayer which controls the CFC could apply for a tax ruling claiming the non-application of the CFC rules. In case of non-UE resident CFCs the Italian-resident taxpayer, which controls the CFC, must give evidence that: - the CFC predominantly carries out, as its main business purpose, an industrial activity within the local market, i.e. within the market of the country where the company is located. The non-resident company must be economically and socially integrated in this market, and the presence of a real business organisation in such market is not enough (c. 51/E/2010). For banks, financial institutions and insurance companies, this evidence is deemed to be given if most of the funds, investments, and proceeds arise from the jurisdiction where these entities are located; or - alternatively, the participation in the CFC does not achieve the result of shifting income to low-tax jurisdictions. In case of EU resident CFCs the Italian-resident taxpayer, which controls the CFC, must give evidence that: - the CFC does not represent a wholly artificial arrangement aimed at obtaining an undue tax advantage (see at Cadbury-Schweppes decision by EUCJ).