The Italian tax authorities issued Ruling No. 86/E on 12 June 2006 concerning the notion of beneficial ownership in Italian tax treaties. (a) The taxpayer's request. A US company (Alfa) requested a ruling from the Italian tax authorities regarding the tax treatment of royalties, received from Italian sub-licensees, under the Italy-United States tax treaty and other relevant tax treaties. (b) Facts.Alfa entered into a contract with a group of licensors not resident in US or Italy, which owned certain patents. Among other things, the contract provided that Alfa has the right to sub-license the patent to third parties. As a...