The tax authorities have addressed, in a ruling issued on October 24 2002 (the Ruling), the tax regime applicable to vehicles incorporated pursuant to the so-called Securitization Law (law no130 of April 30 1999) in order to carry out securitization transactions (the securitization vehicles). Although the Ruling is binding only for the applicant, the principles set forth by same Ruling are helpful in understanding the Italian tax authorities' view, because to date they have not issued any generally binding guidelines.
December 01 2002