Legislative Decree No. 143 of 30 May 2005, implemented the EC Interest and Royalties Directive 2003/49/2003 ("Directive") in Italy, and was published in the Italian Official Gazette No. 172 of 26 July 2005 (Gazzetta Ufficiale). The provisions of the Decree were codified in a new Art. 26-quater of the Italian Tax Assessment Act (Decreto del Presidente della Repubblica No. 600, 29 September 1973, D.P.R. 600/73) and modified Arts. 25, 37-bis and 27 of the same Act.
The Italian Tax Administr…