Proceed with caution

Andrea Tavecchio and Riccardo Barone take stock of Italy’s new tax-monitoring obligations

With its Law Decree No. 167/1990, the Italian government introduced specific legislation on tax monitoring, pursuant to which Italian resident taxpayers are required to report any foreign investments and assets that can generate foreign-source income that is subject to taxation in Italy to the Italian Agency of Revenue. In recent years, the regulations on tax monitoring have been subject to important changes that have not been combined with an update of the Agency’s measure 2013/151663 with the consequence that taxpayers and their professional advisors are now in a climate of interpretative uncertainty. This article aims at analyzing how these changes affect tax -monitoring obligations for subjects with a connection to a Trust.