Italy: Updated “black list” of countries | KPMG | GLOBAL

Italy: Updated “black list” of countries, financial transaction tax

Italy: Updated “black list” of countries

The Italian tax agency issued regulations that update the “black list” of countries or territories for purposes of the financial transaction tax.


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Effective 1 January 2016, the list of “black list” jurisdictions for purposes of the Italian financial transaction tax are any country that is not listed below. This list reflects the fact that Mauritius, Russia, South Korea, San Marino, Liechtenstein, and Croatia have been removed from the “black list.”


Australia Finland Lithuania San Marino
Austria France Luxembourg Slovakia
Belgium Germany Malta Slovenia
Bulgaria Greece Mauritius South Korea
Croatia Hungary Netherlands Spain
Cyprus Iceland Norway Sweden
Czech Republic India Poland United Kingdom
Denmark Ireland Portugal United States
India Latvia Romania  
Estonia Liechtenstein Russian Federation  


The Italian financial transaction tax is levied on transfers of shares or participating financial instruments issued by companies that have their registered office in Italy, regardless of where the parties to the transaction are resident and regardless of where the transfer takes place. The financial transaction tax is also due on transactions involving (1) derivatives whose value is linked to that of such underlying shares/participating instruments, and (2) high-frequency trading. The standard rate of the financial transaction tax is 0.2%. The tax must be paid by the party to whom the ownership of the shares is transferred (the transferee). The tax is either: (1) applied by the financial intermediary (e.g., bank, trust or investment company), or the notary (if any) involved in the execution of the transfer; or (2) paid directly by the transferee. Non-resident intermediaries may appoint a tax representative to handle the financial transfer tax liability. 

When more than one intermediary is involved in the execution of the transaction, the tax is paid by the one who receives the order directly from the purchaser or the final counterparty. Moreover, intermediaries (i.e., banks, investment companies) are considered as purchasers or final counterparties of the execution order if they are located in countries on the black list used for financial transaction tax purposes and are involved in any way in the execution of the transaction.


Read a June 2016 report [PDF 183 KB] prepared by the KPMG member firm in Italy

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