International Investment Opportunities: the new Italian White List
The approval of the decree of the Ministry of Economics and Finance on August 9, 2016, published in the Official Gazette August 22, 2016, significantly updates the list of countries with which Italy has an exchange of information. The new whitelist contains 123 countries compared to the previous 73. Among the new countries included are Switzerland, Hong Kong, Liechtenstein, the Cayman Islands, and Saudi Arabia. This will have a great impact on financial intermediaries who may, for example, be able to exempt from withholding tax Italian real estate funds proceeds paid to pension funds and collective investment undertakings established in blacklist countries.
Another positive aspect concerns the simplification of filling out the RW form by individuals who are residents in Italy. If they hold a participating interest in a whitelist country, these individuals must indicate only the value of the investment. In the event that the country is not on the list, the financial activities and the investments held abroad by the company acting as the dummy corporation must be indicated. This is the so-called “look-through approach”.
We at OAdvisory are here to analyze your fiscal situation to ensure you are compliant with tax laws, also in view of a possible new voluntary disclosure program to be approved by the government, and in light of the greater controls and checks on bank transactions by tax authorities.
The practical effects of this legislation are very important. Italian companies have a new funding channel, and investors have new whitelist havens, which is an excellent opportunity for them, as they can invest in corporate bond issues at a 0% tax rate, whereas previously it was 26%. Even non performing loans, if securitized, may be underwritten by Swiss and Asian investors.
We are available to assist in assessing these and other opportunities.
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