Beginning in 2021, the first reports on cross-border mechanisms with notification requirements will be made, implementing Directive No. (EU) 2018/822 (Dac6). Intermediaries and operators are required to notify the Revenue Agency of so-called notifiable cross-border mechanisms, i.e., schemes, agreements or projects, concerning ITALY and one or more foreign jurisdictions, which have certain characteristics and are directed at obtaining tax benefits. Notifications must be made within 30 days from the day following the day on which the mechanism is made available or initiated or from the day following the day on which they provided, directly or through other persons, assistance or advice for its implementation.
Current accounts without secrets. Between voluntary disclosure and offshore tax investigations, 107 billion euros in revenue has been collected worldwide in 11 years. Hiding money abroad is becoming increasingly difficult: in 2019 nearly 100 countries automatically exchanged information on 84 million financial accounts, totaling 8 trillion euros. The lifting of bank secrecy initiated in 2009 identified 107 billion euros in additional tax revenue. Of this amount, as much as 5 billion euros can be attributed to the last year’s results alone. These are the results of the first review report of the automatic exchange of information on financial accounts in tax matters (Aeoi) released yesterday by the OECD.
In 2019, the effects of the first data exchange in 2018 were evaluated, as the early start of the 2017 data exchange affected a limited number of countries (including Italy). According to the review, 88 percent of the countries engaged in automatic exchange have a satisfactory legal framework. And among them is Italy, which according to the Global forum, is to be considered unimpeachable. Our country did not receive any comments with respect to the quality of data exchange. In contrast, among the EU countries in need of improving their domestic legal framework are Germany, Belgium, the Netherlands, the Czech Republic, Croatia, Estonia, Hungary, Latvia, Poland and Slovakia. Finally, Romania is considered to lack a domestic legal framework on trade.
Under the Aeoi standard, banks report to domestic tax authorities information on financial accounts held by foreign tax residents or, in some cases, held by entities controlled by foreign tax residents. The tax authorities then exchange this information with the tax authority of the jurisdiction in which the account holder is a resident. Access to such data provides the IRS with a tool to verify whether taxpayers have correctly declared their international financial affairs.
In 2020, 105 jurisdictions will exchange information and the network of bilateral exchange relationships has increased by 15 percent to about 7 thousand country relationships. Regarding the 2020 exchanges, countries were able to postpone sending data to the end of December instead of the end of September due to the operational impact of the Covid-19 pandemic on tax authorities and financial institutions.
