On 5 November 2007, the Italian tax authorities issued Ruling No. 312 dealing with the interpretation the new Italian rules on deemed residence (Art. 73(5-bis) of Presidential Decree No. 917/82 (Italian Income Tax Code – ITC)), and Art. 4(3) of Italy-Netherlands tax treaty (DTT).

(a) Facts. A Dutch holding company (the Holding) has its legal and administrative seat in Amster…

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