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 Issuer is indirectly controlled by an EU company. The cash collected by the Issuer for the sale of the bonds was used to secure the bonds themselves. Pursuant to Gibraltar tax legislation, a 35% withholding tax is levied...