May 2010

A decree presented to the Italian Council of Ministers today will introduce new provisions on contemporaneous documentation for transfer pricing purposes and a new black list with a duty to disclose any transaction carried out in or with any black listed countries to the tax administration. Also, the minimum threshold for the duty to report cross border transfers of money will be reduced to euro 5,000.

Italian prosecutors have obtained the list of the bank account holders at the Swiss branch of HSBC. The list has been delivered by the French prosecutor and is said to contain 7,000 names of Italian customers with potentially unreported foreign bank accounts. The list includes a total of 120,000 names.

Italy’s tax administration announced stricter controls on tax refund applications filed on behalf of nonresident persons, and sent a notice to various banks acting as intermediaries in which it requested more information in order to avoid abuse and treaty shopping. As a result, banks may be compelled to identify and disclose information about clients and final beneficiaries of the refund.