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 Italian PE paid interest on (i) loans obtained from the US head office and (ii) loans issued or guaranteed by the shareholders of the US head office. (b) The taxpayer's request.The taxpayer requested a ruling from the Italian tax authority on...