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Administrative assistance:notification from Federal Tax Administration


The Federal Contributions Administration (FTA) today published a second group request from Italy with reference to banking relationships existing with the former BSI AG (hereinafter, EFG AG) on 23 February 2015 and until 31st December 2016. The deadline for regularising fiscal position is due on 30th December 2019.

Information is requested on individuals whose names are unknown and who, in the period from 23 February 2015 to 31 December 2016, fulfilled all the following criteria:

  1. The person concerned was an account holder of (an) account(s) with BSI SA or subsequently with EFG AG;
  2.  The account holder had his/her domicile address in Italy (according to the internal bank documentation);
  3. The account holder was sent a letter in which BSI SA informed about restrictions on banking services unless the account holder had provided the bank with proof of his/her tax compliance;
  4. Despite this letter the account holder did not provide BSI SA or EFG AG – neither before nor after this letter – with sufficient evidence of his/her tax compliance with regard to the account(s).

Exempt are the accounts:

  • Which have been disclosed within the framework of the Agreement on the Taxation of Savings between the Swiss Confederation and the European Union;
  • which have been disclosed within the framework of the automatic exchange of information on financial accounts between Switzerland and Italy;
  • for which an authorisation regarding the specific account(s) has been provided to BSI SA or EFG AG within the framework of the Italian Voluntary Disclosure Program (VDP);
  • for which the overall amount of the account(s) of the Italian taxpayer held with BSI SA or EFG AG has been regularized within the framework of an Italian «scudo fiscale»;
  • for which the owner has provided the Swiss Federal Tax Administration with proof that the assets on the accounts at the end of the last tax year have been included in the income tax return correctly filed with the Italian tax authorities, in particular using the RW model;
  • for which the requested information has already been transmitted to the Italian Competent Authority in a prior administrative assistance procedure.

If the account holder has not settled with the Italian tax authorities and is therefore interested in the administrative request, the FTA sets a deadline for notifying the current address if domiciled in Switzerland or the address of a legal representative in Switzerland by 30 December 2019.

The deadline, set at 20 days from the date of publication in the Federal Gazette, is irrevocable. As stated in the notice, the right to provide the FTA with a foreign address, insofar as it is permitted to serve documents by post in the country concerned, does not apply in this case.

Interested parties may take part in the simplified procedure provided for in Article 16 of the Federal Act on the Free Movement of Persons and consent to the transmission of information to the requesting authority by informing the FTA in writing. Such consent is irrevocable.

This is the second communication from the FTA in a few months. In fact, the last grouped request by the Federal Tax Administration dates back to August: on August 6, the FTA announced that it had received a grouped request from the Italian Revenue Agency regarding accounts held by citizens resident in Italy with UBS Switzerland AG, possibly not covered by the Voluntary Disclosure Program, and held in the period February 23, 2015 until December 31, 2016.

Fidinam & Partners, through its experts, is able to follow you in the process of regularization of your position with discretion, providing you with appropriate tax advice: our experts are ready to assist you by challenging the decision of the FTA or, through our professionals Fidinam Italia, we can help you to regularize the positions in question.

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