The Italian government originally published a list in 1996 – known as the White List – concerning changes to the tax regime for interest, and other income on bonds and similar securities, public and private. A reduced rate of tax was available to income deriving from White List countries, i.e. those countries with which Italy has put in place, by reason of an international treaty, measures providing for an adequate exchange of information regarding a particular taxpayers affairs. Income from countries or regimes not on the list was subject to a higher rate of tax.
Over the years the White List has become a reference point for a number of different tax and tax matters where a favourable tax treatment applies, or where a less favourable treatment applies to countries not on the list.
Italy has implemented these rules recognising her non-discrimination obligations under International double tax treaties. Typically an international double tax treaty contains a clause stating that residents or citizens of the other contracting state must not receive a less favourable tax treatment compared to residents of Italy. For more details and if you would like to read the text of some of the treaties click here.
The states and territories which can be considered white list countries with which exchange of information procedures are in place are shown in the table below.
Note that the legislation is complex and that means a country by country check in the case of any particular tax issue involving another country.
Legislation:
Legislative Decree no. 239 of 1 April 1996
| Italian "White List" Countries (Consolidated List) | ||
|---|---|---|
| A - G | H - P | Q - Z |
|
|
|
Source: Decree of the Minister of Finance of 9 August 2016
The list is subject to modification by subsequent legislation and the exact application of the above list needs to be reviewed in the particular context.