On 28 May 2019, the Italian Revenue Agency published Principle of Law No. 15/2019 concerning the correct determination of a foreign tax credit under Italy's domestic provisions for a tax credit and the tax credit provisions of an income tax treaty (in particular, the Italy-US tax treaty) in cases where Italy's patent box regime is applied.
The Principle of Law provides that in determining a foreign tax credit, the relevant income must be included in determining a taxpayer's taxable income i…