TAILIEUCHUNG - NEW TAX REPORTING REQUIREMENTS FOR FOREIGN INVESTMENT FUNDS DISTRIBUTED IN ITALY

Mutual funds are one of the several options that investors explore for investing surplus funds. In a deposit-dominated market like India it is important for mutual funds to be able to offer differentiated risk-rewards and gain shelf-space. With many seemingly similar offerings from multiple mutual funds unable to clearly communicate their superiority, a less informed investor may find it difficult to make a choice. This uncertainty leads to a weakened ‘pull’ for the product. On the other hand, in an open architecture distribution scenario, distributors are well aware of the differential incentive and brokerage structures across products. After the compensation norms. | Tax perspective New tax reporting requirements for foreign investment funds distributed in Italy Luca Ferrari Trecate Vilma Domenicucci Tax Director Senior Manager Studio Tributario e Societario Advisory Consulting Deloitte Italy Deloitte Luxembourg In September 2011 the Italian parliament ratified a decree law introducing measures aimed at providing financial stability and boosting growth in Italy. These measures form part of Italy s anti-crisis package and included tax reform. Although the tax reform was not specifically intended to impose new Italian tax reporting requirements on investment funds such requirements have been created because of the tax differentiation between direct investment in certain types of securities and indirect investment in the same type of securities through investment funds. Italian tax reform on financial instruments In order to simplify Italian taxation and increase tax revenues the Italian government has introduced as from 1 January 2012 a single harmonised 20 withholding tax rate on income and gains arising from financial instruments which will replace the rates currently applicable and 27 . 54 There is however a major exception a rate of will continue to apply to income arising from government bonds and similar securities including inter alia Italian government bonds Italian public debt instruments Government bonds issued by foreign countries that have agreed to exchange information with the Italian tax authorities Securities issued by international organisations incorporated in accordance with international treaties Piani di risparmio a lungo termine which are newly-created instruments in Italy that are comparable to French Plans d Epargne en Actions or UK Individual Savings Accounts The existing tax rate was not modified by the tax reform with a view to promoting investment in government bonds Italian or foreign and other Italian public debt instruments which are popular with private investors in Italy. Impact of

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