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FTC available for withholding tax levied on interest from black listed country

|Approved Changes|Italy
Italy

On 28 June 2007, the Italian tax authorities issued Ruling No. 147. The Ruling relates to the availability of a foreign tax credit where a final withholding tax on interest has been levied in a black listed country.

(a) Facts. A company resident in Italy for tax purposes (the Purchaser) purchased bonds issued by a company resident in Gibraltar (the Issuer). The Is…

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