22.03.2017

Group Request on “recalcitrant” italian citizens

The Swiss and Italian Fiscal Authority signed an agreement on March, 2nd 2017 to implement the information exchange for tax purposes under article 27 of Convention.

The group requests on Italian citizens may be related to facts and/or circumstances that existed from February 23th 2015 and will regard groups of taxpayers identified as “recalcitrant”. They will identifiable by following criteria (Article 2 of Agreement):

  • Individual who is or was an holder of one or more bank accounts located in Switzerland;
  • Account holder who has or had a domiciled or resident address in Italy;
  • Account holder did not provide Swiss Banks with sufficient evidence of tax compliance.”

The Italian Tax Authority is ready with its first “group requests”, so apply to the Voluntary Disclosure will be the last chance for the Irregular Italian Taxpayer to avoid heavy penalties. 

Our staff is at your disposal to answer any further question about it.
Studio Elvetico Associato

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