Which may not be allowed.
So? What does that have to do with PE rules?
Highly unlikely as that would mean 1/3 of the income of the company would have to be passive in nature. (Hint: You don't know what
CFC rules are.)
They most likely would, or just consider the company tax resident. The company would definitely have to file taxes in Italy, even if it didn't have any profit.
But anyway, let's assume you could actually take out all of the profits as a salary.
It's now only 50%, not 90%, and it's capped at a salary of 600k. You also have to stay in Italy for several years, so no way to run if you don't like it.