The Italian Revenue Agency June 23 issued Letter No. 361/2023, clarifying the determination of business income under the 1999 DTA with the U.S. The taxpayer, an Italian company, contracted with a U.S. company to jointly develop innovative products. As part of the development, the companies issued reciprocal licenses to each other. The U.S. company received income in the form of revenue shares and attribution fees. The taxpayer sought clarification as to whether the revenue shares provided to the U.S. company qualified as business profits or royalties subject to withholding tax. The Tax Agency clarified that the revenue shares didn’t qualify …