Tax agreement Italy-Switzerland enters into force

With the publication of the ratification law in the "Official Journal", the tax agreement Italy-Switzerland, mainly for the exchange of information between the tax authorities of Rome and Bern, entered into force.

The rule is that until 2018, the two countries will exchange information on request only, both on an individual basis and in groups while starting from 2018, the exchange will become automatic. To use the data obtained in this way, however, it can only be the judicial or administrative authorities which had requested them.

The rule will also apply retroactively, but only until 23 February 2015, when the Milan Protocol was signed by both parties. The new rules also provide that the rights of taxpayers provided for by national laws can not be violated. Who hopes to "hide" but aspects to cheer: the measure is not intended to "prevent or delay effective exchange of information." The Swiss Confederation, in fact, can no longer refuse to provide information to the Italian authorities "just because held by a bank, financial institution, nominee or person acting as agent or trustee."

The new law, however, has not yet said its last word, at least in theory, up to July 7, there is still the possibility of a referendum to abrogate. However the experts consider the possibility as a rather remote.

 
By a separate agreement should be dealt with other tax issues currently under discussion, such as the taxation of frontier workers and residents of Campione d'Italia, as should a provision on the limitation of conventional benefits in case of abuse (the so-called Lob clause).