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| Malta, Cyprus Off Italian Blacklist |
by Ulrika Lomas, Tax-News.com, Brussels
Monday, August 02, 2010
The Italian Ministry of the Economy has issued amendments to the relevant legislation,
by which Malta and Cyprus have been removed from the country’s ‘blacklist’
of tax havens.
The Ministry has made the appropriate changes to all three lists of countries
considered to have tax systems which favour the avoidance of taxation - that
concerning the residence of individual taxpayers; the list valid within the
tax legislation concerning controlled foreign companies (CFCs); and that regarding
the non-deductibility of corporate costs and expenses.
Cyprus and Latvia have also been eliminated from the blacklist of countries
with which Italy does not have a sufficient level of tax information exchange,
while South Korea has been taken off the CFC and corporate cost lists.
Malta and Cyprus, which are also full member states of the European Union,
will now have fully ordinary fiscal status as far as the Italian tax system
is concerned. In particular, with effect from this tax year, those Italian individuals
who have attempted to transfer their residence to one of those countries will
not have a continued presumed residence in Italy, while there will be no additional
tax consequences for those Italian businesses with subsidiaries or associated
companies in Malta or Cyprus.
The changes to the lists are also significant with regard to the new Italian
value-added tax (VAT) reporting requirements that were announced in April, for
all 'risky' import and export transactions above EUR50,000 (USD65,400), particularly
those transacted with countries considered not to have a sufficient level of
tax information exchange.
Under the new rules, the details of transactions in goods and services from
companies or individuals having an establishment, residence or domicile in those
countries will have to be forwarded electronically to the Italian Revenue Agency.
As it stands, therefore, transactions with Luxembourg, Liechtenstein and Switzerland
in Europe will still have to be reported when the system comes into effect.
Although those VAT arrangements have now probably been delayed from August
31 until October 31, it should also be noted that San Marino remains on the
blacklist, despite all of its efforts to negotiate with the Italian government
on what remains to be done before it can regularize its standing with
Italy.
A comprehensive report in our Intelligence Report series
tracing in detail the course of the last six years both globally and at jurisdiction
level, explaining precisely what you get - and don't get - for your money in
all of the main offshore jurisdictions, is available in the Lowtax Library at
http://www.lowtaxlibrary.com/asp/subs_reports.asp
and a description of the report can be seen at
http://www.lowtaxlibrary.com/asp/description_report1.asp
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