Following on from numerous representations made to the Italian
authorities, neither Guernsey nor Jersey will be listed on any
Italian 'black list' from 1 January 2016. In addition
Guernsey and Jersey will be included on a 'white list' for
the purposes of tax treatment of interest from Government bonds and
listed companies when that list is updated in early 2016 by
The changes approved by the Italian Parliament on 22 December
2015 under its Stability Law 2016 revise Italy's rules on
corporate taxation and Control Foreign Companies ("CFC")
and abolish its so called 'black lists' with effect from 1
Given the level of co-operation extended on tax information
exchange, both on request and automatically, by Guernsey and
Jersey, together with their well-developed and robust regulatory
regimes governing the provision of financial services, the
continued inclusion of Guernsey and Jersey on Italy's
'black lists' could not be justified. Accordingly,
the changes announced by the Italian authorities at the start of
2016 are warmly welcomed by governments and industry alike.
*NOTE The inclusion on a black list of
third countries by certain EU Member States became a significant
issue when the EU Commission published last year a list which
purported to identify on a pan-European basis third countries which
were deemed to be non-cooperative by virtue of inclusion on certain
national lists. As a result of representations made in
response to the Commission's list, including by the UK
Government and the OECD, the validity and usefulness of that list
was questioned and indeed in September last year, the Commission
agreed to review the future of the pan-EU list. The removal
of Guernsey and Jersey from Italy's black list supports
Guernsey's and Jersey's view that inclusion on such lists
is "unjustified, unwarranted and plainly wrong"
(Guernsey's Chief Minister, 6 July 2015).
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Maltese tax law provides for rules which grant beneficiaries referred to as ‘Highly Qualified Persons' to be taxed at a reduced rate of tax of 15% on their employment income, provided certain conditions are satisfied.
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