精东影业

In recent weeks, the Agreement signed between Italy and Liechtenstein regarding the exchange of information and group requests has regained concrete relevance, as the Italian Tax Authorities have submitted a specific request for exchange, which the Liechtenstein Authorities are currently processing. It should be recalled that Law No. 210 of November 3, 2016, ratified the Agreement between the Italian Government and the Government of the Principality of Liechtenstein on the exchange of tax information, signed in Rome on February 26, 2015.

The Agreement is based on the OECD Model Tax Information Exchange Agreement (TIEA) and allows for information exchange on request between the two countries for all taxes. An integral part of the Agreement is the additional Protocol on 鈥済roup requests,鈥� whereby Liechtenstein allows group requests concerning accounts held by an Italian resident individual with financial intermediaries in Liechtenstein, for the period between the date of the Agreement鈥檚 signing (February 26, 2015) and the implementation date of the automatic information exchange Agreement between Liechtenstein and Italy based on the OECD Model (effective as of 2017).

Under this Protocol, Italy is proceeding with group requests targeting Italian tax residents, the so-called 鈥渞ecalcitrant鈥� taxpayers, who have never responded to requests from financial institutions for adequate assurances regarding the legitimacy of funds held with the relevant financial institutions and who held an account as of February 26, 2015. The group requests pertain to tax years still subject to review by the Revenue Agency in light of the extension of the statute of limitations for tax assessments and violations related to tax monitoring as set forth by Article 12 of Legislative Decree No. 78/2009.

During the webinar, the fiscal and criminal consequences arising from the exchange of data requested through group requests will be addressed, considering that, under the aforementioned extension of terms, violations related to 2015 income taxes (i.e., false declaration), although nearing the statute of limitations, may still be subject to assessment by the Revenue Agency. Additionally, the omitted completion of the RW section for tax monitoring purposes must be taken into account, with the statute of limitations extending until December 31, 2026, for 2015, as well as cases of omitted declaration, which also allow the Revenue Agency to apply extended assessment deadlines.

Speaker
Pierpaolo Angelucci
Certified Public Accountant, Scarioni Angelucci, Associated Tax Firm, Milan

Cost
CHF 150.-
Discount of CHF 50.- for members of partner organizations

Registration

Registration Deadline
Friday, November 22, 2024