Treaty between Italy and Tunisia – Italian tax authorities rule on whether domestic tax credit is available on portion of prélèvement fiscal global

forfaitaire related to impôt sur les sociétés paid by Tunisian PE

On 7 March 2008, the Italian tax authorities issued Ruling No. 83 regarding the domestic tax credit available on foreign taxes paid by a foreign permanent establishment.

(a) Facts. An Italian company is involved in the construction and enlargement of a pipeline in Tunisia and in the transportation of gas to Tunisia through a pipeline representing a fixed establishment in Tunisia. It follows that the Italian…