scudo fiscale

 I understand your worries, though I believe Jersey has jumped through the requisite hoops to not be considered 'on the grey list'. (That isn't just an Italian thing). I don't think (unless your client is an Italian national) that the 5% 'import tax' should be applicable - it is basically designed to sanitize money which Italian tax-payers have, in the past, hidden out of Italy. I'm not expert in this stuff in any way: it might be worth your while paying the €3 for the IlSole pdf on the current scudo, but meanwhile you could trawl through this stuff! http://www.ilsole24ore.com/dossier/Norme%20e%20Tributi/2009/scudo-fiscale/ http://www.ilsole24ore.com/art/SoleOnLine4/dossier/Norme%20e%20Tributi/2009/scudo-fiscale/glossario/glossario-scudo-fiscale3.shtml?uuid=3f41acee-a13f-11de-a8df-36fb8db592ee&DocRulesView=Libero

Thanks Fillide - I too thought it was just for Italian nationals, but I read the text of the law and it clearly says 'residents'.  Also Tremonti seems to be getting a bit trigger happy with his definitions, as I have Swiss clients who llive here, and receive a Swiss pension - they now have to pay 5% on their pension if it comes into Italy which is absurd.  I assumed there must be a minimum threshold of say 1 million euros, but it seems that any money coming in from a non Schengen country is liable.  Lawyers tut and shake their heads, but I assume that is just lawyers for you.  The trouble is, how can you prove its not a repatriation if the money was taken out illegally.  It technically means that any sum coming into Italy could be reptriatiion and is therefore liable to the tax, if you have been resident since before December 2008.   I dont want to give my clients wrong information, and Im certainly not a tax expert - however being ITaly, noone seems to know the letter of the law! 

 I should have been more precise and said Italian (tax) resident, and not Italian national, sorry. There are also various lists of countries, (paradisi fiscale, Cee which is EU plus Norway and Iceland, and 'collaborativi'). Neither Switzerland nor Jersey are on the Agenzia list of collaborativi - if that makes any difference.