The Italian tax authorities (ITA) have revoked, with ruling 159/E of July 25 2003 (the New Ruling), their previous ruling dated December 13 2000 (the Previous Ruling). The Previous Ruling addressed a transaction (the Share Exchange) whereby an Italian company (the Contributing Company) transferred to a beneficiary company resident of a different EU Country (the Beneficiary Company), the controlling stock of another company (the Controlling Stock), solely in exchange for the Beneficiary Company's shares (the Shares).
August 31 2003