Tax treaty between Italy and US – Italian ruling on concept of beneficial owner (royalties)

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 …