On 8 August 2007, the Italian tax authorities issued Ruling No. 212 that deals with the deductibility, for corporate income tax purposes, of the costs incurred by the Purchaser for the acquisition of a financial lease contract (the "Costs").
(a) Facts. During the fiscal year 2006, an Italian resident company (the "Purchaser") purchased a financial lease contract originally stipulated by the Seller in 2003. The Purchaser paid a price of EUR 541,000 exc…