Reference
Beneficial owners that are residents of Switzerland are eligible, among others, to apply for tax exemption on interest and other proceeds on Italian bonds subject to DL 239/1996.
Background
An additional Protocol was signed in Milan on 23 February 2015, amending the Convention against Double Taxation signed between Italy and Switzerland in Rome on 9 March 1976.
This new Protocol establishes, in line with the OECD Standard, the exchange of fiscal information between Italy and Switzerland, including the so-called “information relevant for the administration and/or application of their respective taxation laws of any nature and denomination, collected in Italy or in Switzerland” in accordance with art. 27, paragraph 1.
Following the ratification of the above mentioned Protocol, starting from 13 July 2016 by the Law 69 dated 4 May 2016, Switzerland has been excluded from the Black List and has been included in the Italian White List related to the exchange of fiscal information that implies stopping of the Bank secrecy.
The Italian Ministry of Finance published the updated White List Countries including Switzerland. The list is available on the Italian Tax Authorities website.
Impact on customers
Beneficial owners that are resident of Switzerland holding Italian debt securities subject to DL 239/1996 may apply for tax exemption.
The operational details of the concrete procedure to be followed are currently under investigation and will be published in a follow-up announcement.
Further information
For further information, please contact the Clearstream Banking1 Tax Help Desk or Clearstream Banking Client Services or your Relationship Officer.
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1. Clearstream Banking refers collectively to Clearstream Banking S.A., registered office at 42, avenue John F. Kennedy, L-1855 Luxembourg, and registered with the Luxembourg Trade and Companies Register under number B-9248, and Clearstream Banking AG (for Clearstream Banking Frankfurt customers using CreationOnline), registered office at 61, Mergenthalerallee, 65760 Eschborn, Germany and registered in Register B of the Amtsgericht Frankfurt am Main, Germany under number HRB 7500.