The New Reporting obligations of the Italian Beneficiaries of foreign Trusts and Italy s Voluntary Disclosure Programme

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1 The New Reporting obligations of the Italian Beneficiaries of foreign Trusts and Italy s Voluntary Disclosure Programme STEP BENELUX 14 th May 2014 LUIGI BELLUZZO TEP Belluzzo&Partners

2 1. Exchange of Information 2

3 BACKGROUND According to official estimates, assets worth at least EUR 200 billion are currently held abroad and not declared in Italy by resident taxpayers. The market decline in bank secrecy and the strengthening of exchange of information between States have exposed such individuals to the real risk of discovery and subsequent administrative and criminal action. It is likely that Italy will introduce the new criminal offence of self-laundering in the near future. A draft law has already been circulated and the Law Decree n. 4/2014 actually introduced the Italian Voluntary Disclosure procedure ( collaborazione volontaria ), but has not been converted into Law by the Italian Parliament. Nowadays two drafts Laws are pending for discussion. Italian Authorities are acting powerfully to bring Italian business on the right (tax) track and delivered a combinated approach, following the Laws. Among these the new rules for the Foreign Assets Reporting (RW or Monitoraggio Fiscale) accurately introduce peculiarity which eventualy let the taxpayer or the ultimate beneficiary to disclose his or her foreign assets. May

4 Italian Voluntary Disclosure

5 BREACHES In almost all cases those Italian private taxpayers (and similar entities, according to article 4(1), of the Law Decree N.167/90) holding undeclared capital abroad have breached regulations as follows: failure to make tax returns and the payment of taxes in Italy on income giving rise to financial assets and income from these assets; failure to comply with tax monitoring regulations pursuant to Legislative Decree No 167/1990 and amendments; probable commission of criminal offences pursuant to Legislative Decree No 74/2000. May

6 2. Foreign Assets Tax Reporting (RW) 6

7 INTERNATIONAL REPORTING Recent amendments to the tax monitoring regulations under European Decree No 97/2013 have rendered voluntary disclosure more attractive, since the applicable sanctions have been notably reduced. Sanctions for failure to submit tax returns or for filing of incomplete returns (for direct taxation, and VAT where applicable) are much more lenient under this law, given the voluntary nature of the procedure. According to experience there is an high degree of attention to the immediate future of the structures held by the taxpayer as the Administration is asking for security about the future taxation of income related to those assets. Recently the reporting obligations rules (RW) following Law n 97/2013 have been commented by the Tax Autorities (Circular 38/E of December 23 rd,2013). More information is avaiable on our web site (FOCUS B&P Magazine). May

8 ADMINISTRATIVE SANCTIONS for failure to report assets held abroad (RW) Article 9 of Italian Law N. 97/2013 (so-called Legge Europea ) modified the fiscal monitoring and reporting legislation, by introducing much more lenient sanctions for failure to submit the RW Form with the indication investments and financial assets held abroad, as follows: from 3% to 15% for assets held in countries on the white list; from 6% to 30% for assets held in countries on the black list (DM 4 TH May 1999 and 21 st November 2001); application of sanction for failure to complete Section II of the RW Form only; confiscation of equivalent value does not apply anymore. May

9 RIFORMA QUADRO RW Following an assesment to restore a breach from the Italian Gov t of the EU rule, we finally had a reformed Law Decree n. 167/90 about the obligation to report about foreign assets for an iialian resident taxpayer. Artile 9 of Europea Law n.97/2013 modified the Law Decree n.167/1990 about the so called «moniotraggio fiscale». The new rules: simplify and reduce burder for compilance for Italian residents about foreign assets and/or financial activity abroad; extend obligations for the filing of Model RW to ultimate beneficiary too. They have to report for the various cases disciplined by the so called III Directive. extend reporting also below the Euro threshold, with the only exception of bank accounts and deposit. There is not any more the relevant picture at year end, but it is sufficient to have assets one day only. New rules starts to be effective from January 1st 2013!!! 9

10 RIFORMA QUADRO RW Obligations for International Reporting: a) Individuals resident in Tax Italy; b) Non commercial entities resident in Tax Italy; c) Non commercial companies (società semplici) tax resident in Italy And other similar taxpayers Direct or Indirect Ownership OR Ultimate Beneficiary 10

11 RIFORMA QUADRO RW L ambito soggettivo Ultimate Beneficiary Taxpayer is obliged to verify il only for one moment/day in the relevant year he or she or it is the beneficiary owner Company Other Entities: Trust, Wrappers, Foundations, etc la persona fisica (o le persone fisiche) che possiede o che controlla società attraverso il controllo diretto o indiretto di una percentuale pari al 25%+1 di partecipazione al capitale la persona fisica (o le persone fisiche) che esercita il controllo sulla società in modo diverso da quanto sopra specificato. la persona fisica (o le persone fisiche) beneficiaria di non meno del 25% del patrimonio, nel caso in cui i futuri beneficiari siano stati già determinati La categoria di persone nel cui interesse principale agisce ed è istituita l entità giuridica, nel caso in cui i beneficiari non siano stati individuati La persona fisica (o le persone fisiche) che esercitano un controllo su non meno del 25% del patrimonio di un entità giuridica Very Important: we have to consider the whole family, according to art. 5 Tuir ( coniuge, parenti entro il III grado, affini entro il II grado). 11

12 3. Trust and RW 12

13 RIFORMA QUADRO RW L obbligo dichiarativo B) The LOOK THROUGH APPROACH and the ULTIMATE BENEFICIARY Requisiti del controllo non verificati Non Commercial Trust (and similar structures) are obliged to monior directly foreign assets and invesments sono tenuti a monitorare direttamente gli investimenti o le attività estere (se si tratta di enti non commerciali residenti). Requisiti del controllo verificati the Taxpayer is obliged to monitor through RW: the whole value of foreign investments through the trust; the percentage of the benefit The look through is always activate for black listed structures, trust, wrappers and foundations (and similar structures) 13

14 B) INDIRECT OWNERSHIP RIFORMA QUADRO RW L obbligo dichiarativo Through a Trust If we are before «not determined beneficiaries» the Trust must report (RW) Through income trasparent resident Trusts Obliged TaxPayer Condition Indicazione nel quadro RW Trust Beneficiaries are NOT ultimate beneficiaries The total asset values; The specific % which is without «beneficiaries». Beneficiario Beneficiaries are ultimate beneficiaries The total asset values; the specific % 14

15 RIFORMA QUADRO RW L obbligo dichiarativo o Foreign Trusts with «determined (capital) beneficiaries» in Italy Obliged TaxPayer Condition Indicazione nel quarto RW Beneficiary The determined beneficiary is redisdent and attributed with a relevant participation (25% or more) of trust assets The total asset values; the specific % Beneficiary Beneficiary is not «ultimate beneficiary» the attributable % of the trust fund 15

16 Q&A 16

17 Dedicated Belluzzo&Partners Here at Belluzzo&Partners we prepared a dedicated team highly skilled in cross border tax matters and benefiting from the positioning of the firm in England and in Italy. We are recognized by top International directories among top Italian tax firms with expertize on estate planning, trust, tax and inheritance issues. We are also able to recruit colleagues with dedicated expertize to single issues both on crime law and civil law issues. We can therefore advice both trustees, banks and/or beneficiaries with a particular attention to culture and language, with a technical approach and the ability to manage the whole process from initial contact with UCIFI officers and tax litigation procedures to the definition of the Italian Voluntary Disclosure and its effects. With a particular focus to the (soft) landing in Italy for International offshore structures previously planned. Further it is possible to find solutions where structure became Italian under a tax structure, retaining its International jurisdiction, giving comfort to International trustees and generally to clients.

18 Stradone San Fermo, Verona T F Via Cordusio, Milano T F , Craven Street WC2N 5NG London T F Our firm operates in Italy as a Professional Association of Accountants and Lawyers and in the UK as an LLP. Further information, including details of equity partners, is available on our website or from our offices. Our firm has correspondents in over 100 countries worldwide. We are a founding member of RETIS Professionisti Italiani nel Mondo, a non-profit consortium linking top Italian firms across the globe. May 20014

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