Black List Costs – sanctions applicable to the past

Starting from 2016 the anti-tax-haven rules have been repealed.

So today the new regime provides the full deductibility of the blacklist costs and furthermore the elimination of the obligation, previously required, to report separately blacklist costs on the tax return, and abolition of the related sanctions.

Nevertheless the circular n. 39/E/2016 issued by the Italian Revenue Agency confirmed that the sanctions will still be applied to the past.

So with reference to the periods prior to the year 2016, the sanctions related to the omission of the separate reporting of the blacklist costs, and the fraudulent tax return, in case the black list costs were considered not or partially deductible, will still be applied.