Italian Voluntary Disclosure: Act Now Before It Is Too Late

Following the example of other OECD countries, Italy introduced a voluntary disclosure programme at the beginning of 2014. 

The deadline for applying under the Voluntary Disclosure ('VD') programme is due to expire on 30 September and although the Italian Government is mulling over an extension, this cannot be guaranteed. Therefore, taxpayers should consider acting now.

The latest developments are set out in two Circular Letters, which clarify a number of practical issues.

Powers of attorney over bank accounts

With the second Circular Letter (published on 16 July 2015), the Italian Tax Authority clarified that anyone holding a power of attorney over a foreign bank account may apply independently under the VD even if the proxy had never actually been used. Whilst any income tax violations would be attributed to the beneficial owner of the account, the proxy holder will be able to avoid any sanctions for failing to report the existence of the account under the