San Marino Talks To Italy, While Switzerland Suspends DTA Negotiations

by Ulrika Lomas, Tax-News.com, Brussels

04 November 2009

While San Marino has continued its dialogue with Italy concerning tax residency, the Swiss government, headed by President Hans-Rudolf Merz, has suspended all negotiations with the Italians on a double taxation agreement following the recent investigative action against Swiss banks in Italy.

The outcome of the meeting on October 29, between representatives of the Italian Revenue Agency and San Marino’s Secretary of State, was said to have been collaborative and positive. Discussions centred on an analysis of the detailed information available concerning the fiscal residence of certain Italians in San Marino.

From an analysis undertaken by San Marino, the number of Italian citizens resident in San Marino (who do not have dual residence) is estimated to be around 3,500.

Following this meeting, it was decided that the Revenue Agency would concentrate on the cases which would seem to represent the highest risk; that is, presumably, where there could be significant funds involved.

On the other hand, with regard to Swiss-Italian relations, following the recent operation by the Revenue Agency and the Italian Financial Police (Guardia di Finanza), which involved the investigation of the foreign business of 76 Italian offices of Swiss financial institutions, Swiss President, Hans-Rudolf Merz, has announced that Switzerland has suspended all on-going negotiations with Italy on a new double taxation agreement (DTA).

In an interview with the Blick newspaper, he argued that the Italian action was clearly discriminatory against Switzerland. As a consequence, conclusion of the new DTA, which includes clauses for the exchange of tax information and was ready for ratification by Switzerland, has been suspended until further notice.

Hans-Rudolf Merz has also appointed Renzo Respini as his political adviser for all matters concerning the fiscal situation with Italy.

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Tags: Italy

 






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