jueves, 6 de octubre de 2016

Italy updates "white list"

An updated version of the “white list” of jurisdictions that allow an effective exchange of information with Italy (established through a decree dated 4 September 1996) has been issued through a ministerial decree dated 9 August 2016 and published in Italy’s official gazette on 22 August 2016. Investors resident in white-listed jurisdictions may be eligible for various tax benefits in Italy.

The new version of the list includes jurisdictions with which Italy recently has concluded exchange of tax information agreements (including the British Virgin Islands, the Cayman Islands, Hong Kong and Switzerland). The 2016 decree also provides an option for the Italian tax authorities to remove jurisdictions from the white list that do not carry out an effective exchange of information with Italy.

The applicability of several beneficial Italian tax measures is based on the residence of a foreign investor in a whitelisted jurisdiction, the most important of which include the following:

  • A full exemption from substitute tax on interest paid to entities resident in white-listed jurisdictions on Italian government bonds and bonds issued by Italian banks or Italian resident entities;
  • A full exemption from withholding tax on interest paid to entities resident in white-listed jurisdictions on deposits and current accounts (other than those held with banks and the postal service) and on payments for any type of guarantee;
  • A full exemption from tax on capital gains from the sale of nonqualified participations in Italian private companies (i.e. holdings of less than 20% of voting rights or less than 25% of economic rights) by entities resident in white-listed jurisdictions; and
  • A full exemption from withholding tax on amounts paid to specific qualified white-listed investors by certain Italian REITs

The date from which the updated white list applies is unclear – since the decree does not provide any specific date for its entry into force, it arguably is applicable from the date of publication in the official gazette (22 August 2016).

Source: Deloitte

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