On 26 April 2007, the Italian tax authorities issued Ruling No. 80 having as its object the tax treatment of (i) an Italian permanent establishment (PE) of a UK partnership, and (ii) income paid by the UK partnership to the Italian partners.
(a) Facts. The UK partnership carries out, in the UK, a professional activity (legal consultancy). Pursuant to UK tax legislation it is treated as a transparent entity and, therefore, its income is taxed in the hands…