(June 24, 2015)

On June 23, 2015 the Government of the Isle of Man issued a news release announcing that the Agreement between the Government of the Isle of Man and the Government of the Italian Republic for the Exchange of Information Relating to Tax Matters (hereafter: the TIEA) entered into force. According to the news release the TIEA entered into force on June 10, 2015.

Based on paragraph 1 of Article 3 of the TIEA the taxes which are the subject of this Agreement are:

(a)    in Italy:

(i)            the personal income tax;

(ii)          the corporate income tax;

(iii)         the regional tax on productive activities;

(iv)         the value added tax;

(v)          the inheritance tax;

(vi)         the gift tax;

(vii)        the substitute taxes; and

(b)    in the Isle of Man:

(i)            the taxes on income or profit; and

(ii)          the value added tax.

Paragraph 2 of Article 3 of the TIEA determines that the TIEA shall also apply to any identical or substantially similar taxes imposed after the date of signature of this agreement in addition to, or in place of, the existing taxes. Furthermore, the taxes covered may be expanded or modified by mutual agreement of the Parties in the form of an exchange of letters.

Article 5 of the TIEA contains regulations regarding the Exchange of Information upon Request, Article 6 contains regulations regarding the Possibility of Conducting Tax Examinations Abroad, Article 7 contains regulations regarding the Possibility of Declining a Request, Article 11 contains regulations regarding a Mutual Agreement Procedure.

Based on the information as provided by the Government of the Isle of Man (that the TIEA entered into force on June 10, 2015) the TIEA shall have effect:

(a)    for criminal tax matters on June 10, 2015; and

(b)   for all other matters covered in Article 1 of the TIEA on June 10, 2015, but only in respect of taxable periods beginning on or after June 10, 2015, or where there is no taxable period, all charges to tax arising on or after June 10, 2015

For further information click here to be forwarded to the text of the Agreement between the Government of the Isle of Man and the Government of the Italian Republic for the Exchange of Information Relating to Tax Matters as available on the website of the Government of the Isle of Man.

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