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