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 Tu…
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