On 10 May 2007, the Italian tax authorities issued Ruling No. 93 having as its object the interpretation of Art. 15 of the Agreement between the European Community and the Swiss Confederation providing for measures equivalent to those laid down in Council Directive 2003/48/EC on taxation of savings income in the form of interest payments (the "Agreement"), published in the Official Journal of the European Union L. 385/30 of 29 December 2004. (a) Facts. An Italian resident company is 50.01% owned by a company resident in the Swiss Confederation and 49.99% owned by a company resident in the United States...