On 9 January 2007, the European Commission announced that it had sent Italy a formal request to implement the Interest and Royalties Directive (Council Directive 2003/49/EC of June 2003) (the Directive) correctly (case reference number 2006/4136). The Directive aims to abolish the taxation of interest and royalty payments made between associated companies of different Member States in the Member State of source and thereby to ensure the equal tax treatment of domestic and cross-border transactions. Italy implemented the Directive by legislative Decree No. 143/2005 and restricted its scope of application to interest and royalty payments accrued (having become payable) on...