OrbitaxThin capitalization rules not applicable to interest paid by Italian PE to US head office; deductibility of interest expense under transfer pricing rules analyzed
|Treaty Development|Italy-United States
The Italian tax authority issued Ruling No. 44 on 30 March 2006 regarding the applicability of thin capitalization rules to the Italian permanent establishment (PE) of a non-resident company (the "US head office").
(a) Facts.The US head office is a US public company, Alfa & Company, which exercises its activities in Italy through a PE situated in Italy. The …
