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After almost three years’ negotiations over untaxed Italian assets in Swiss banks, Switzerland and Italy have reached an agreement in principle on future cooperation in tax matters.
The agreement between Switzerland and Italy was initialled on 19 December 2014
The two governments are currently preparing the signature of a Protocol of Amendment to the double taxation agreement which should be signed before the deadline set for Italy's voluntary disclosure programme on 2 March 2015.The double taxation agreement (DTA) between Switzerland and Italy is to be supplemented by a protocol that makes provision for the OECD standard for the exchange of information upon request.
"After years of controversy, this agreement should improve relations between Switzerland and Italy in relation to financial and tax matters - says Alessandra Bellanca, Partner in the E.U. Tax Team - It will simplify the regularisation of untaxed assets before the automatic exchange of information is introduced and limit risks’ exposure arising from legal proceedings for banks and their employees"
When the new Swiss-Italian tax agreement will enter into force, Switzerland will be removed from Italian black lists and it will lead to an orderly transition to the future automatic exchange of information and to a simplified regularisation of Italian bank clients' assets without massive outflows of capital.
The Swiss-Italian DTA contains the following clauses in particular:
From the Italian taxpayers’ point of view, the agreement will considerably increase legal certainty for Italian taxpayers who have an account in Switzerland. This agreement is the precondition to reduce the taxable period for Italians with secret accounts from 10 years down to 5 years only. Furthermore, Italy will allow Italians to maintain their account relationships with Swiss banks because Switzerland is now considered as cooperative country.
For the Swiss banks, these will be authorized to retain tax compliant funds of Italians still in Switzerland.
For more information about the double taxation agreement (DTA) between Switzerland and Italy, please contact in strict confidence: Alessandra Bellanca, Partner in the E.U. Tax Team (a.bellanca@giambronelaw.com).