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Investing in China

By Gareth Horsfall - Topics: Investments, Italy
This article is published on: 16th August 2021

16.08.21

Is communism the way forward?

Whilst on holiday, peering out over turquoise bays, ones mind starts to wander and what better route to take than pondering whether communism really has some postive aspects which we, in the capitalist world, would do very well to replicate.

I think my mind has had the space to wander into this rather philosophical space because there has been little to discuss on the Italian tax front (one of my favourite topics). We are waiting for the big announcement on exactly how Mario Draghi intends to overhaul the tax system in Italy and that decision is ‘supposedly’ being announced shortly (but will likely take longer than expected, as is always the case in Italy!). As soon as I know anything I will let you know.

So to continue my thought wanderings I thought we should talk about China.

But before I get into the detail, I want to write about a conversation I had with some clients (who shall remain nameless), who took a long trip along the old Silk Road some years ago. They had been amazed at the development they had seen along the old route, and that it had mainly been funded by China. They also travelled in China itself and commented on the magnificence of its technological and infrastructure progress. These clients, who I would say could easily be classified as socialists and defenders of free speech, said that given what they had seen and the speed at which China can just ‘get on and do things without arguing about it’ does make you wonder ‘if there is some merit to their form of communism’.

And with that thought in mind, this E-zine will explore some of those aspects of Chinese governance. This E-zine was inspired by a blog post I recently read from an asset manager called David Coombes at Rathbones Asset Management (a collaborative partner to The Spectrum IFA Group). His blog puts some recent issues surrounding China’s political decisions in a new and interesting light.

investing in china

So what is happening in China?
Late 2020, Chinese regulators stepped in and forced Ant Group, a digital payments spin-off from ecommerce giant Alibaba, to abandon its stock market listing on the Shanghai exchange. More recently ride-sharing app Didi Chuxing was pulled from Chinese app stores days after it brushed aside regulatory concerns about data security to list on the stockmarket in New York. In addition, the Chinese authorities have levied a record $2.8 billion fine on Alibaba for anti-trust violations, and regulators are investigating food delivery app Meituan and internet and gaming conglomerate Tencent for the same issues.

Not only are they attacking the tech industry but the government, in an overnight decision, seemingly abolished ‘for-profit’ education in core subjects for kids up to 15 years old, sending an entire private education industry into complete chaos.

Many investors are concerned about a wider crackdown across multiple industries.

investing in china

The way of the Dragon!
Before we become too shocked by how the Western media portray decisions by the Chinese government, it is a good idea to look at the problems from a Chinese perspective rather than only through our Western lens. China, in much the same way as the West, is struggling with the tremendous power that Chinese online giants now wield over various sections of society. They have created a kind of ‘winner-takes-all’ online marketplace in technology and data. Equally Chinese families are now have to pay increasingly large fees to send their children to school to get even a half decent education.

Does all this sound too familiar?

If so, let me ask you a few questions:

* Do you think that big tech firms( Amazon, Google, Facebook, Apple etc) play a much too important role in our lives and do you think they should be more heavily regulated in the way they keep and use our data?
* Do you think that big tech firms should pay more tax?
* Do you know anyone with kids who is paying a fortune for private education? From supplementary English, sports or music lessons and /or having to pay a small fortune in nursery costs to secure a place in a good nursery school for their kids?

investing in china

Technology
I don’t know many people these days who can easily defend the growing, and rather worrying power of the tech companies in and on our societies. I, personally, am concerned about the use of data, the power of their lobbying and their continued ‘legal’ tax avoidance (Amazon paid an effective tax rate of 1.2% in 2020 when their marketplace exploded with Covid stay at home policies, which drove even more people to online shopping!). Yet, in many ways we are slave to these beasts. I couldn’t run a business without them, and they do make life much easier.

Education
The Chinese authorities felt that competition in education was putting too much pressure on children and creating a financial drain on parents that is possibly slowing the birth rate and affecting property prices. This was putting children of less wealthy parents at a huge disadvantage. Sounds oh so familiar! Some ‘3 year old’ Chinese children were receiving extra tuition to prep for entry exams to get a place in kindergarten. The Chinese government says this was having a negative impact on the social cohesion of the country. As a father, I think I have to agree!

China does what the West keeps talking about
Could it be that China have looked at the Western model and decided it would like to introduce more regulation to benefit families and the populous, instead of corporations? Given they are named the ‘Central People’s Government’ one might be forgiven for thinking that they are looking at putting people first and corporate expansion second. Wouldn’t it be nice if our own governments could do the same?

investing in china

Do you prefer democracy or dictatorship?
The truth of the matter is that Chinese leaders don’t pull any punches when they want to implement new policy. They don’t need to put it to a public vote; they can do it overnight. This means that businesses, small and large, suffer hugely as a result. I would be very worried as a father, contributor to the family purse and businessman if the Italian government had the power to introduce legislation which effectively put me out of business overnight.

So, what do I prefer: democracy or dictatorship? In all honesty, I think I am a middle-ground man. I don’t think either work well. I think I would probably choose to compare socialism versus capitalism as economic models and once again, I don’t think either work well in the extreme. I think that we live in an advanced capitalist society in the West which should be reigned in through more regulation in these new and influential sectors. What is perpetually annoying is that I work in financial services which is one of the most heavily regulated businesses and yet we have the big tech firms, the new world of ‘influencers’ and the online world which is largely unregulated and can operate in whichever way it pleases. Maybe China has got it right and they are trying to create a more socially cohesive society.

So should you still invest in China?
You could actually think of the Chinese Government intervention as ethically responsible politics. It is focussing on inequality and trying to improve society as a whole. If you look at it through that lens, then Chinese investment starts to look quite appealing.

That being said, it would be foolish to say that this doesn’t come with some inherent underlying risks. Which industries / sectors might they attack next? And what about corruption, unquestionable power, individual rights etc? That is why it is important that when allocating a part of your portfolio to China, you must be precise – you can’t just buy a Chinese market tracker and expect explosive returns. It is a large market, but one that is still maturing. Company governance is going to have to improve from here or authorities won’t just fine you, they will close you down (or your whole industry!).

So whatever Western media might have us believe, it might just be that this inequality / social-pact shake-up is a sign that China might be a better place to invest over the next decade. And whilst we always advise caution when investing, in line with your own risk profile and using well established, competent asset managers, I would expect to see some allocation to China in almost everyone’s portfolio.

And on that note, it just leaves me to wish you a Buon ferragosto and I hope you manage to stay cool in the ‘Lucifero’ African anticyclone currently covering the country. Keep your anguria close at hand! As I write this E-zine, I notice that the hottest ever recorded temperature in Europe has been set in Siciliy at 48.8 degrees Celcius! PHEW!

As always, if you have any questions about this E-zine, or would like to contact me about your financial and/or tax planning needs in Italy, then feel free to get in touch on gareth.horsfall@spectrum-ifa.com or on cell +39 333 649 2356.

Moving to Italy and the average cost of living

By Gareth Horsfall - Topics: Italy, Moving to Italy
This article is published on: 12th July 2021

12.07.21

You have made your tax calculations for life in Italy, but have you included everything?

In this video Gareth talks about the costs of living in Italy and how it varies depending on where in Italy you want to live.

He also explains that whilst it is almost impossible to calculate until you are living here, it has the same effect as a tax reduction and should be taken into account when making your decision about life in Il bel paese.

If you are interested in moving to Italy or perhaps already live here,
but need to discuss some financial areas of concern,
please use the form below to contact me.

    The Spectrum IFA Group is committed to building long term client relationships. This form collects your name and contact details so we can contact you about this specific enquiry. For further information, please see our Privacy Policy.
     

    Tax Reporting in Italy

    By Gareth Horsfall - Topics: common reporting standards, Italy, Tax in Italy
    This article is published on: 4th June 2021

    04.06.21

    Excuses that will not fly with the Agenzia delle Entrate

    You wouldn’t believe it, but I started venturing out last week. I actually visited some clients and spent time with people, in the flesh, who exist outside my social bubble! It really was quite a bizarre experience because the first thing that hit me was that apart from the fist bumping and/ or deliberate distancing, that the relationship had not changed one iota. It was business as usual, which I found odd at first because after everything we have been going through I assumed that maybe that things would have changed a bit. I am now totally convinced that it will be business as usual once this phase passes!

    So I am going to let life take steps to getting back to normal and move onto important financial matters. This article is entitled ‘Excuses that will not fly’ because since tax reporting time is upon us again, I thought I would look at the most common excuses that I have heard over the years when it comes to reporting taxes correctly…and I have heard a few! I also want to cover the Common Reporting Standard again, what it is and why it is very important that you get the tax reporting right every time.

    Excuses, excuses
    I have to be honest and say that I have heard probably every excuse possible for not having made tax declarations in Italy, and whilst in many cases I do actually feel quite sorry for the person, because it is a genuine mistake mainly due to lack of knowledge, excuses will not fly with the Agenzia delle Entrate (AdE), no matter what your intentions were.

    tax reporting Italy

    So here are the top excuses that the Agenzia delle Entrate do not care about.

    1. I didn’t know I had to.
    This has to be at No 1 because it is the most common one I have heard over the years. Needless to say the AdE has no interest in whether you knew you had to do something or not. It is your responsibility to get informed, and failure to take the right advice or do the right thing means you are liable for all back taxes if they catch up with you.

    2. I am not a tax resident.
    I have written about this many times in the past. If you are registered as resident in Italy, i.e. you have registered at the comune and are registered at the Anagrafe, then you are more than likely, in the eyes of the AdE, going to be considered fiscally tax resident as well. Just because you live in another country for more than 183 days per calendar year and your main work and/or family interest are outside Italy, it does not matter to the tax authorities. You have registered to say you are resident and therefore they can legitimately come after you for taxes.

    I was recently contacted by someone who said that she had been registered as resident in Italy since 2007, when she bought a house, but the home had only ever been used as a holiday home (she was informed by the estate agent that if she registered as resident then she would only have to pay 2% VAT on the purchase rather than 9%). However, the registration meant that she was also fiscally tax resident. The tax authorities have recently contacted her to ask for all back taxes in the last 5 years on her worldwide incomes, assets and gains.

    The only way to resolve this now is to put a case forward to demonstrate than she was UK tax resident and falls under the double taxation treaty. That will likely mean lawyers and accountants needing to get involved and an extensive negotiation with the AdE and the UK tax authorities. In addition, they can legitimately ask for all the taxes to be paid whilst the situation is resolved.

    One simple rule to remember is that if you want to simply own a holiday home and have no intention of becoming a fiscal tax resident in Italy then do NOT, under any circumstances, register as resident at your comune!

    **A small note here, just to say that because of Brexit a number of Brits asked me about taking residency, pre 31 December 2020 as a way of getting around the travel restrictions imposed by the EU for non-EU citizens: 90 days in 180 day travel in the Schengen area. The answer is very simply that it is not possible unless you want to be on the radar for taxes as well. It is an all or nothing situation!**

    3. I am covered by the double taxation treaty (DTA) between my country and Italy, and therefore considered non-resident.
    This is one that I also hear often and stems from a misunderstanding of the DTA. The tie-breaker clause in the DTA states that where two states cannot agree on the residence of an individual then a number of criteria will be applied to determine the residency of the said person.

    This might seem cut and dried, but if you register as resident in Italy but maintain your family/work/social and business interests in another country it DOES NOT mean that you automatically fall under your home country rule. In reality Italy, as any other country, could ask you to pay your taxes for your time registered as resident. You would be expected to pay and then deal with the respective tax authorities to reach a ruling as to exactly where your actual residence lay in those years. The important part to note is that, if asked, you would be expected to pay your outstanding taxes and then claim them back! Better to plan your residency carefully before a permanent move or a simple house purchase.

    4. My commercialista told me not to declare it.
    This is another well-worn example of getting informed before you decide a course of action. The simple rule with the commercialista is that whatever they ‘advise’ must be written down either in an email or on headed paper and signed. The excuse that they told you not to do it, which you later find out not to be correct, will not pass AdE inspection. In addition, if it isn’t written down then you have no come back against the commercialista if they have advised you incorrectly. All commercilisati have to hold professional insurance in the case of them giving bad advise, but no evidence, no claim!

    Commercialisti are in general good at what they do, but you may find that your local firm is more knowledgeable about running a local agriturismo business than how to advise ‘stranieri’ with their overseas tax declaration. I now speak and intermediate with my clients’ commercialisti to ensure a) they know what products they are dealing with and b) how they should be declared. Most commercialisti are willing and want to learn and very frequently tell me something I was not aware of either.

    One quick rule: If your commercialista tells you that you don’t have to declare something then go and find another one. Everything needs to be declared in Italy!

    5. I pay tax already on my house in the country where it is located. Why I should pay the Italians as well?
    I can’t recount how many times I have heard this one and whilst I understand the feelings around paying taxes in one state and then having to declare them again in Italy, these are the rules. Property is a fixed asset, and by fixed I mean physically fixed to the ground (unless it’s a caravan!) and therefore you must, by law, declare the asset and income from it in the country where it is located, first. Once you have been through that process you then need to declare it in Italy in the same way. If there is a double taxation treaty between Italy and the country in which the property is located, and it covers property specifically, then you should be able to claim a tax credit for any tax paid. You will therefore end up only paying tax in Italy at Italian rates.

    I often hear people tell me that their commercialista has said that they cannot deduct expenses in Italy. This is correct. If your property is located in the UK, for example, then you cannot deduct any UK generated expenses ‘directly’ in your Italian tax return. However, this misses the point that they can still be deducted. You can and should still apply allowable expenses in the UK (in this example). In Italy, you report the UK income generated after UK allowable expenses.

    6. I don’t want to declare that for tax in Italy, it was a gift.
    This is one I don’t hear so often but it comes up every now and again. You may have received a gift from someone or received an inheritance as part of the distribution from an estate and obviously taxes may need to have been paid in the state where the estate is administered. Once you receive the money then it needs to be declared in Italy in whatever form you choose to hold it, annually. The gift/inheritance will not be taxed again as Italy respects the fact that taxes have already been paid on the gift/inheritance. Therefore, not declaring the monies you receive doesn’t make any sense and would be merely seen as a deliberate attempt to hide money from the tax authorities.

    7. My ‘stranieri’ friends have been living in Italy for years and none of them pay tax in Italy.
    These excuses are not in any particular order because if they were then this one would be nearer the top of the list. It’s a common one and makes me sigh with despair every time I hear it. It is also my favourite!

    The chances are that your friends are not doing what they should be doing and it is only a matter of time before they get picked up by the tax authorities. I know there are plenty of people who are living in Italy, and have been for many years, without having made any declaration to the Italian state. I don’t think I need to say that this is 100% illegal and is advice that should not be followed!

    For EU nationals, taking the risk of hiding under the EU Freedom of movement directive seems to be an option that some are happy to take. They remain resident in their home country but live in Italy all year round. Admittedly, I think they would be hard to find, but then they are not registered in the Italian system, are unable to buy a car or claim on the state for medical or other benefits.

    Those people who are registered as resident, but also failing to declare themselves as fiscally tax resident in Italy are in a much more precarious situation and given the recent example, (as highlighted above in excuse No 2), then it is not a position that I would want to be putting myself into.

    For non-EU nationals, then it is cut and dried. If you obtain a Permesso di Soggiorno to remain in Italy for over 6 months a year, then you are fiscally tax resident. If you fail to declare your taxes in Italy, and are subsequently contacted by the Agenzia delle Entrate, then you can’t say that you weren’t warned.

    I think that finishes the list of excuses. Clearly it is not a definitive list. I am sure there are more but these are the most frequent that I hear. I hope that they provide you with some direction if you are wondering about what or how to declare in Italy. I have a very simple mantra which I stick to which may also help you:

    IF IN DOUBT DECLARE THE ACCOUNT!

    common reporting standard

    The Common Reporting Standard

    In this next part I want to go over some old ground, but which will put what I have written above into context and show why getting your declaration right in Italy is becoming more and more important.

    I remember well, during the spring back in 2014/15 when I was contacted by a large number of people who had recently been contacted by the Agenzia delle Entrate (AdE) for unreported assets in their Italian tax return, or in a high number of cases, failure to even submit an Italian tax return for income/assets that they held overseas.

    This is now happening again but with more rigour!

    This is all coming about because of The Common Reporting Standard and Automatic Exchange of Information (AEOI).

    These are international agreements that were developed by the 34 member states of the Organization for Economic Cooperation and Development (of which Italy was one) via its permanent “Global Tax Forum”. AEOI was designed to help combat cross-border tax evasion by individuals who were not reporting and paying applicable taxes on assets held through non-domestic financial institutions, whether these assets are held in the name of the individual or through certain offshore entities such as companies, trusts, foundations, partnerships and similar. It is primarily focused on individuals and “passive” income (i.e. dividends, interest, capital gains, etc.). It came into force in 2017 but information was backdated to the 1st January 2016.

    How does Italy know if I have assets abroad?
    Have you been contacted in the last few years to provide your TIN. (Tax Identification Number) to your overseas bank and/or financial institution? I have, on numerous occasions! If you a resident in Italy this number is your codice fiscale in the UK it would be your National Insurance number and in the US, your social security number, to name a few.

    It is now a legal requirement to provide your TIN number on any financial contracts that you adhere to, be it banks accounts, investment portfolios, insurance policies, or other financial instruments. I have a small investment account with Hargreaves Lansdown in the UK and was recently contacted by them to update my codice fiscale. Through an error in their systems they had failed to pick up on the fact that I had given it some years ago, but they were refusing to allow me access to my account if I did not provide it again. It got resolved, but it shows you how seriously this is now being taken when financial institutions will block access to your accounts if you don’t provide them with the information needed to share information with the correct tax authorities.

    data privacy

    What information will they share about me?
    Under the Common Reporting Standard the financial information reported includes the name, address and tax identification number (where applicable) of the asset owner; the balance/value, interest and dividend payments and gross proceeds from the sale of financial assets. The financial institutions that need to report include banks, custodians, financial institutions, investment entities such as investment funds, certain insurance companies, trusts and foundations.

    The tax authority will receive much more information than ever before and even simple bank account balances showing money coming in and out can raise red flags and the AdE can choose to investigate where the source of the money came from.

    Is this new?
    Exchange of financial information across Europe has been going on for a long time now and can be traced back to the introduction of the European Savings Tax Directive 2005. The Common Reporting Standard is an enhancement of this.

    I remember that in 2012 when I was contacted by a number of UK rental property owners who had been legitimately declaring their UK property income in the UK for tax purposes. However, as residents in Italy they had not declared anything because they didn’t know they had to. A clear exchange of information took place and the Guardia di Finanza did a significant number of visits to these people to fine them.

    ***This is also happening again this year! We are seeing the AdE issuing letters for unreported income going back as far as 2015/2016***

    ***The Covid crisis has sharpened the eyes of the tax authorities as they are now searching desperately for more tax revenue lost through the pandemic. We have seen AdE activity rise since the start of the year and even seemingly small mistakes on tax returns or undeclared assets are being investigated***

    Low hanging fruit!
    Remember that with the kind of information that the tax authorities are receiving from one another, we really are the lowest hanging fruit to pick from. Easy pickings! So, my advice is always the same. The past cannot be corrected but you can change your future. Hiding and hoping the problem will go away is not an option. The only solution is to get your financial situation ‘in regola’.

    What will I pay?
    How you declare your money and how much you will pay to regularise your situation is a question that can only be answered by a commercialista, but it does make sense to have a look at your whole financial situation beforehand to see what damage limitation you can do by planning efficiently as a tax resident in Italy.

    “Never look back unless you are planning to go that way”

    Do you have non-euro based cash deposits?

    By Gareth Horsfall - Topics: Italy
    This article is published on: 29th April 2021

    29.04.21

    Inspiration for this article came from a client (they often do) who fell into one of those sneaky little finance laws in Italy that not many know about, nor really pay much attention to, including the Agenzia delle Entrate (AdE) so it would seem.

    However, laws are laws and as I have written many times before, the rollout of the Common Reporting Standard in 2016: the international accord to share financial and tax information between different countries is appearing more and more on my radar. I now get a steady stream of people who say they have received a letter from the AdE asking them to declare their financial position regarding assets/monies held abroad.

    In the case of the subject of this article, this is not a law which has, as yet, been specifically identified by the AdE, but one might argue it is only a matter of time.

    Non-EUR based cash deposits

    €51645,69 or 1 million lira

    The figure quoted above is important in relation to how much money you hold in deposits in foreign currencies (cumulatively) at any one time.

    There is a part of the Italian tax law (L’art.67, comma 1-ter del Tuir) relating to the application of capital gains taxes and capital losses, which would appear to be little understood by most.

    The law states that where you hold over €51645,69, (1 million lira equivalent) cumulatively, in foreign currency accounts (non EUR) for a ‘period of over 7 days‘, then when you transfer any of that money into EUR (or another currency), the amount exchanged is automatically subject to the calculation of capital gains tax (or losses) in Italy, because the transaction of changing money from one currency to another itself, is assumed, after 7 days of the money being held in deposit, to be a speculative transaction as the result of a ‘trading operation’ instead of merely a conversion of currency for any other means.

    How do I calculate my gains?

    This is where it gets a bit complicated as you might imagine and is not quite as simple as the image above would make you believe.

    Without wishing to go into too much detail in this E-zine, you take the amount of euros (or other currency) that you end up with in your account ‘after exchange’, but then need to refer to a EUR cost of those monies at the time at which you originally received that foreign currency. You convert that sum into EUR using the Banca D’Italia exchange rate on the specific date or dates when they landed in your account, depending on whether you received the funds in one go or if they were accumulated over time.

    As you might imagine this could be hellishly complicated if you have been receiving monies in from various sources over a period of time. However, reference would have to be made to each deposit in non-EUR currency, and a EUR equivalent calculated on the day when it was deposited in the account. In the case where deposits are not documented, for whatever reason, then the Agenzia delle Entrate will refer to the worst monthly conversion rate to EUR for that said currency, in the tax period in which the liability arises (i.e. calendar year). This could work in your favour in some cases, and create additional tax liabilities in others, so care needs to be taken.

    Finally, if you do not convert all the funds in your foreign currency account into EUR then the ‘last in first out’ principle applies. This means you must refer to the latest deposit/s in any of your foreign currency accounts, which equate to the sum which you have exchanged to EUR or other currency, and use the Euro conversion value on the date that those funds arrived in your account.

    Sound complicated?

    It is!

    The client I referred to at the start of this email was pulled up by her bank because the bank itself, Fineco, is Italian, and therefore where they see or suspect a specific activity they must warn the client that they need to take remedial action (in this specific tax case it is the declaration on the Modello 770).

    In truth, a lot of you are using various currency exchange services, the most recent being Wise (ex-Transferwise). They are not an Italian institution and therefore are not obligated to tell you about this law, should it apply to you. The onus is on you to ensure that you make your tax declarations correctly and timely. However, without working knowledge of laws such as this one, then it is unlikely that you are going to do what you are supposed to do unless advised by someone like myself, or your commercialista highlights the fact to you.

    I hold more than €51645,69 in non-Euro deposits – what do I do now?
    Before we start worrying about any capital gains tax or losses, there is the usual requirement to ensure that any foreign currency accounts are declared in your tax return every year and you pay the €34.20 ‘bollo’ per account.

    In addition, we have this extra requirement that if you do hold ‘more than‘ €51645,69 in foreign currency deposits in any one calendar year, you are a resident in Italy, and have held the funds on cash deposit for more than 7 days, and exchange some of that deposited money into another currency (euro or any other) then you have an obligation to calculate any potential profit/loss as a result of the exchange.

    To avoid this law the simple answer is to bring the euro value of your foreign currency deposits under this €51645,69 and ensure they stay under every year.

    If you are potentially in this situation then it might simply mean looking at your overall financial planning and whether you a) need to keep high deposits and b) seeing if you can find alternatives, such as money market accounts or low risk investments, whilst meeting any shorter term cash requirements that you may have.

    Do you have overseas assets and are living in Italy?

    By Gareth Horsfall - Topics: Italy
    This article is published on: 11th February 2021

    11.02.21
    Lazio zona gialla

    I thought I would write about the colour yellow in this E-zine.

    I never knew how much I liked the colour yellow. It had never really come on my radar until Lazio moved into ‘zona gialla’ again on the 1st February.

    This lockdown has been quite challenging in many ways but it has really made me appreciate the small things which enrich our daily/weekly/monthly lives and break the daily monotony. For me, it’s those meals out with family, friends and clients, those mid-week trips to the cinema to see a film that has been newly released or a special theatre trip because some performing artists are in town. And I have to admit (I never thought I would ever write this) that I actually miss those kids parties when the parents lurk around at the back of the room talking and the fathers sneak off to have a beer or a glass of wine (or 2). Oh, and not forgetting those little trips, overseas or in Italy, that have been off the table now for sometime, but are the icing on the cake of life. I long for the day when I can make, even short trips away, with the family and friends again.

    What’s New

    Anyway, enough of my Covid colour thinking.

    Well, if you have missed it, there is a new technocrat government in Italy. This time under the supervision of Mario Draghi. For anyone who is unfamiliar with Mario Draghi, he is the last ex-President of the EU Central Bank, previous head of the Bank of Italy, previous economist for Goldman Sachs and has also worked at the World Bank. If you are interested, he also has a house somewhere near Citta delle Pieve, Umbria.

    What’s interesting about this appointment is that he was the man who pretty much stopped the EU crisis of 2012, merely by announcing that the ‘Within our mandate, the ECB is ready to do whatever it takes to preserve the euro. And believe me, it will be enough’. With those words he stopped the attack on Spanish and Italian government debt, being launched at the time by the worlds financiers, and prevented a complete meltdown when Greece was also in fear of default.

    There is no doubt that ‘Super Mario’ (his other widely known name) is a very adept politician and economist who has the ability and knowledge to get Italy out of it’s current predicament, as a result of Covid.

    It was Matteo Renzi who pulled out of the coalition which was keeping Giuseppe Conte in power and managing the Covid crisis, but Renzi being a ‘supposed’ pro-business politician didn’t think that Conte had the ability to manage the €266 billion Recovery fund which is shortly arriving from the EU, and which will be used to help rebuild the economy. I happen to agree (although I think Conte has done a good job of managing the pandemic in Italy) and also believe that Mario Draghi is probably the best person for the job.

    However, to what extent he will be prevented from doing so by the warring parties is anyone’s guess. He is a no nonsense economist/politican and has already made it clear that he wants to surround himself with capable people, and not politicans who are looking to advance themselves or their parties.

    I suspect he will get some new and interesting projects approved by Parliament, but like the technocrats before him (Letta and Monti), will eventually be stopped by the other political parties who will want to merely push their own agenda and take power.

    But, let’s not take this step for granted because if Mario Draghi is given enough leash to enact some serious recovery plans, and real effects can be seen, then they may give him more leash than we might expect.

    My thinking is that alot of the burden will now be placed on his shoulders, and should he be able to magic the economic bunny out of the crumbling Italian economy top hat then the other political parties will quickly amass like children around a fresh birthday cake, to benefit from his good work and look to ultimately grasp power and take all the credit.

    It’s all to play for. I shall be watching this one carefully. I think like most of us who have been living in Italy for quite some time, we really hope that something significant happens because we see so much potential for change.

    UK Offshore territories

    UK Offshore territories
    For anyone holding money in the UK offshore territories: Jersey, Guernsey, Isle of Man, British Virgin Islands, Cayman Islands etc, you should be aware that the EU voted to put these territories back on the EU black list as of the 1st February 2021.

    www.theguardian.com/world/2021/jan/22/meps-vote-to-add-channel-and-british-virgin-islands-to-tax-haven-blacklist

    I suspected that this would be the case once the UK lost its protected status in Brussels and these territories, which depend on the UK, have been now put back on the EU’s black list. Essentially this means that they do not share adequate financial information and lack sufficient fiscal transparency. By keeping arrangements in these jurisidctions you will be subjecting yourself to punitive tax rates as a resident in Italy.

    If in any doubt then you can always contact me on +39 3336492356 or on email gareth.horsfall@spectrum-ifa.com

    Agenzia delle Entrate

    Letters from the Agenzia delle Entrate
    Someone forwarded me a forum discussion chat the other day which was discussing the fact that British citizens around Italy were receiving letters from the Agenzia delle Entrate and being targeted in a campaign for undeclared finances.

    Firstly, I should say that I do not have any insight into what the Agenzia delle Entrate (AdE) is doing or thinking, but can only hypothese based on past experience.

    One thing I think it is fair to say is that I don’t think that the AdE is actually targeting British citizens living in Italy as a result of Brexit. What is more likely the case is that the AdE are doing what they do most years, at the start of the year, and send out standardised letters to foreign citizens resident in Italy with the hope that they will pick up somebody who has undeclared income/assets and/or gains.

    I myself have received 2 of these letters in the past. The first proved to be a mistake, the second however, put me in such a panic that I went back over my finances for the previous year with a fine toothcomb and realised I had mistakenly failed to declare a small dividend payment in the UK, but it should be said that there was no mention of this error on their letter. The letter itself was a standard letter merely saying that as a result of information gained from the exchange of information between tax authorities, it was ‘believed’ that I may have undeclared assets/incomes and/or gains and that I needed to regualrise my affairs. It was enough to make me look back over everything and get everything ‘in regola’ .
    I know that in the last few years the Italian authorities have become more sophisticated with the information that they have received and so should you receive a letter with specific figures mentioned, then I think it is fair to say that you have been caught and you will have to provide the information requested. It would also make sense to get a commercialista to help submit the information and negotiate with them on your behalf, if required.

    However, if you receive the generic letter then it could just be that they are on a ‘fishing’ mission. Setting a cat amongst the pigeons, pick one off and the rest become so much more wary. In my opinion, any letter from the Agenzia delle Entrate should not be ignored. It could certainly be the case that they are party to information which has been shared by tax authorities in other countries where you hold assets and so to ignore such a communication could land you in very hot water indeed.

    My simple message for anyone, to prevent ever receiving a letter from the Agenzia delle Entrate is

    ‘If in doubt, declare the account’
    (And don’t forget your other worldwide assets/gains and income too)

    tax in italy

    Imposte and Tasse
    Do you know the difference bettwen your ‘imposte’ and your ‘tasse’?’. In English they are both taxes, but in Italian they have different meanings and so it is probably a good idea to understand what the difference is.

    Tasse are taxes which are collected to fund a specific part of the Italian state. A good example is TARI (Tariffa sui Rifuiti) or even airport taxes. They are collected for the purpose of funding a specific part of the Italian state infrastructure.

    Imposte,on the other hand, are generic taxes which are charged but which have no specific objective in mind, other than to fund the ongoing cost of the Italian state. These would include things like IRPEF (income taxes) IVAFE (wealth taxes) and IVIE (a tax on property).

    So, the next time you have a chat with your commercialista, or when you are chatting in the bar about how much we have to pay in taxes in Italy, you can make sure that you use the right terminology for the correct type of of tax!

    Understanding Italian tax legislation

    By Gareth Horsfall - Topics: Italy, Tax in Italy
    This article is published on: 22nd January 2021

    22.01.21

    I normally like to start a new E-zine or article with a story or some kind of recent experience to try and provide context to what I am about to write. However, because of my lack of travels, I am lacking stories at the moment. In fact, I am now starting to believe that there is a government conspiracy to bore me to death, or they are in collaboration with Netflix to lobotomize me with endless series and films. Lockdown phase 2 is proving somewhat monotonous!

    So, with the fact that there isn’t really much to tell you other than work related matters, then we might as well crack on, because the truth is that as a result of Brexit a number of financial things have changed. A lot of my clients are now non-EU citizens (i.e. Brits), and so a better understanding of Italian tax legislation is essential. We have done some extensive digging in this regard and our investigations have sprung up some unwelcome news for some.

    The information we found was buried so deep in Italian tax law text that it took us (in reality my colleague Andrew Lawford ended up discovering it through sheer determination and persistence) quite some time to dig it up. So make sure you read the whole E-zine as something might be relevant to you.

    I should add that the financial services industry is still trying to work itself out and we should remember that there is no deal for financial services as part of the Brexit trade agreement. A lot of hope is being placed on a potential trade agreement being reached on financial services by the spring, as professed by Rishi Sunak, but I have my doubts.

    UK Banks closed

    SO, WHAT ARE THE CONCERNS?
    Let’s start with the one that got the most press leading up to Brexit. The automatic closure of UK bank accounts for EU residents.

    There is not much to say here, other than the main culprits seem to be Barclays, Lloyds, Nationwide, Royal Bank of Scotland and Halifax. To date, my experience with clients is that the closure letters are a bit of a scattergun approach. Not everyone I know with an account in these banks is being approached to close it.

    I am asked a lot about the possibility of using a UK address of a relative or friend and whether this would alert the bank to you living in the EU or not? The likelihood is that it will for 2 reasons. The first is that under the Common Reporting Standard (International sharing of tax and financial information) banks only need to ‘suspect’ that you are resident in another country. This might be determined from activity on your account, or other financial information that they may receive from foreign tax authorities. The second reason is that ultimately you should be asked to prove the address you provide. A simple check on the land registry can avert them to the fact that you are not the registered owner of the property. A standard requirement is to request a copy of a utility bill showing your name and address on it or some kind of official tax authority document. If you are unable to prove these, then the chances are that the banks will catch up with you sooner or later.

    So, what are the alternatives? I have recommended Fineco as a good Italian bank alternative (for transparency purposes, I have been an account holder for approx 10 years) but I believe that more of you than ever are finding it easy to open and use Transferwise as a transitionary online solution. But it’s NOT a bank, so beware! There are online banks as well, such as N26 and the online offshoots of the regular Italian banks. There are certainly lots of options available although finding a non-UK alternative that will allow UK direct debit payments is pretty much impossible.

    taxation on overseas rental property for Italian residents

    UK PROPERTY OWNERSHIP
    I have written previously about this and the increased wealth tax that will now be charged on UK property ownership for Italian residents.

    To recap, in a pre-Brexit world a UK property owned by an Italian resident would have had a wealth tax charged against it each year, in Italy. The value for calculating this charge was 0.76% of the council tax value of the property. This is considerably lower than the market value in most cases. However, now that the UK has left the EU the method for calculating that wealth tax changes.

    Properties that are located outside the EU are subject to the same charge, 0.76%, but in this case the valuation basis moves to the purchase/acquisition value of the property, where provable, and the market value otherwise. For most people I am finding that this is quite a difference, and for anyone who has bought in the last 10 years or so, this means a mostly, higher annual wealth tax charge. To date, I have only come across one person who retired to Italy and had retained the family property in the UK for many years, and could benefit from a very low purchase value for calculation purposes, hence a net tax benefit as a result of the tax change post Brexit. Most are going to find that their cost of holding UK property will increase as a result of the UK leaving the EU.

    tax-italy-guide

    TAX BREAK…
    For anyone inclined to sell their UK property then we shouldn’t forget that there is the possible ‘sale-of-home’ tax break as an Italian resident. If you have owned the home for more than 5 full tax years then Italy does not consider a property sale speculative (even a property located overseas) and so no capital gains tax is charged in Italy. You may have tax applied in the country in which the property is situated, in which case you would need to check the local tax laws. In the case of the UK, a property sale as a non-UK tax resident means capital gains tax would be charged on the property, but only from the date at which the legislation was introduced: 6th April 2015. What this means is that any gains made up to that point can effectively be written off, and the cost value for the purposes of calculating the capital gain would be the value as at the 6th April 2015 or later, depending on when you bought the property. A handy tax break for anyone who has held property in the UK for more than 5 years.

    UK IFA

    UK IFAs
    Now, we come onto the more technical points and an area which I see evolving over the coming year/years: UK IFAs (Independent Financial Advisers).

    Even when the UK was inside the EU it was not uncommon for me to come across people who had existing relationships with UK based IFAs who advised them on their finances, in the same way that I do for my clients living in Italy. But, even inside the EU most firms were not licensed to work with clients who were living in an EU state (it was easy enough to check on the Financial Conduct Authority website in the UK), and even in the few limited cases where they had the licence they did not have any experience of the Italian tax and financial system, so their advice was mainly useless and normally bad for the client. However, many continued to operate regardless, protected (loosely) by being a member of the EU.

    Fast forward to a post Brexit world and the fog has cleared. If you are working with a UK based IFA, and living in Italy, then you should not be receiving any advice from them. They will not have the necessary authorities or licences to operate in the EU, and as such, you as a client are not protected for any advice that they give you. This has been very clearly highlighted in a Banca D’Italia document which was released at the end of last year.

    If you do work with any UK based financial professional it would be in your interests to contact them and ask if they have an EU based entity to ensure they can continue to work with you. In much the same way as the banks are pulling out of the EU (the ones that have no intention to develop or maintain their existing EU business), IFA firms (small or large) should also be doing the same.

    I have to admit, that I have benefited from this because a number of UK firms with Italian resident clients have already contacted me about passing on their clients because they are no longer able to work with them. I expect this to continue as more firms understand their legal liability of working with clients in an un-licensed capacity.

    If you are in this situation please speak with the firm and/or send me a message and I can help you to look into it in more detail.

    investment talk

    ASSET MANAGERS
    This is a category, very similar to UK based IFAs. These are firms which generally manage sizeable portfolios for clients and have a direct relationship with the end client. To date there are mixed messages coming out of this sector. Some asset managers are aiming to pass EU based clients to EU based firms, like ourselves, others are clinging onto various legal loop holes to retain business. If you have a portfolio managed by a UK based asset manager directly, then the best you can do is to contact them and ask them what their post Brexit plans are. We expect that over time the EU will develop a more protectionist and hardline stance on working with non EU based firms.T his will ensure that they can more readily protect their EU residents and citizens and also win business from the UK.

    Where UK asset managers are used inside Italian tax compliant accounts, in the way that we mostly structure assets for our clients, then you do not have to worry as the provider of the account will be keeping abreast of legislation as it changes.

    ***For all my clients, please be aware that we are on top of any changes in this regard and you do NOT need to contact your asset manager as a result of the content in this E-zine. If anything changes we will notify you as soon as we become aware. We also have contingency plans in place should any changes need to be made***

    italy tax

    TAX ON UK DOMICILED ASSETS
    This is probably the most revealing piece of information that we have discovered, and whilst it is new for UK residents, it has always been the tax case for other non-EU Italian residents e.g. US citizens. And very important information it is as well for the holders

    of UK domiciled non-property assets (excluding bank accounts).

    We are not sure if most commercialisti are aware of what we discovered and so we encourage you to have a discussion with yours if you think you might be affected!

    Essentially, if you hold non-EU approved investment funds in a portfolio with a bank or an asset manager, then these same assets must meet 3 simple rules for the flat 26% tax treatment for investment income and capital gains to be applied, in Italy.

    1. The fund or collective investment must be established in a member state of the EU or EEA
    2. It must be sold in Italy under the relevant distributions guidelines from the regulator CONSOB
    3. And if you are working with someone who manages your money they need to be subject to EU authorisations in the country in which they operate from

    And the important point to note is that any investment fund must be covered under all 3 criteria and not just one!

    What is the consequence if your collective investments don’t meet these criteria?
    Very simply all your investment income and capital gains are added up and taxed at your highest rate of income tax! They are added to all your other income for the year and taxed accordingly. For someone who is earning up to €15000pa (pensions, rental income and/or employment income) then this would be advantageous, but for any figure above then your tax rate will be higher than the 26% currently charged on the same asset.

    How can you check if you have a non-EU domiciled collective investment asset?
    Very simply, all securities are allocated an International Securities Number (ISIN code). You will need to check that yours starts with an EU approved code, such as IE, LU, FR, IT etc. For any UK citizen living in Italy holding securities/funds or assets, whose code starts with the letters GB, then it might be time to take another look at your financial planning as a resident to try and mitigate any future tax charges on these assets.

    And that’s it for this E-zine! There are quite a few financial planning considerations to be taken into account here and so I will elaborate on them in future E-zines, but if you have any doubts as to whether any of these topics may apply to you, or want some help looking into anything, then I would suggest you get in touch using the form below.

    Are you a UK IFA with Clients Living in Italy ?

    By Gareth Horsfall - Topics: Italy, UK IFA
    This article is published on: 8th January 2021

    08.01.21

    ARE YOU UNABLE TO SERVICE THESE CLIENTS POST BREXIT?

    UK IFA

    At The Spectrum IFA Group we can look after your clients long term as licensed and regulated financial advisers operating in Italy.

    The things you should know before you contact us for our help:

    • We specialise in financial planning for English speaking expatriates across western Europe
    • We are locally authorised in all jurisdictions in which we operate and across the entire EU (and Switzerland). Our regulatory status is unaffected by Brexit
    • We hold financial services licenses for both insurance mediation (Insurance Distribution Directive compliant) and investment advice (MiFiD compliant)
    • Established in 2003, we have 50 advisers and 12 regional offices
    • We work only with large, well known asset managers including Blackrock, Jupiter, Fidelity and Prudential. For clients with higher value portfolios we also use discretionary investment managers such as Rathbones, Smith and Williamson and Quilter Cheviot
    • As part of our terms of business, clients of The Spectrum IFA Group receive ongoing, long term service and support. All advisers live within easy travel distance of their clients
    • We are not an offshore broker. We do not use products from UK dependant territories (such as the Isle of Man or Channel Islands) as they can produce adverse tax consequences for clients living in Europe. We advise that you don’t use any of these structures for your clients if they are EU resident
    • We use only locally compliant products which are designed specifically for the jurisdictions in which our clients are based
    • We work on a transparent charging structure with all clients. Charges are deducted directly from the products and solutions we recommend. We do not invoice separately
    Why should I be wary of exchange rates?

    As the end of the transition period is rapidly approaching we ask that you contact us as soon possible to allow time for us to complete any necessary restructuring of client assets.

    If your clients are resident in the EU or Switzerland, or intending becoming resident, please feel free to contact us for a no obligation discussion to determine if we can look after your clients post Brexit.

    You can contact me at gareth.horsfall@spectrum-ifa.com

    How is my UK Pension taxed in Italy?

    By Gareth Horsfall - Topics: Italy, UK Pensions, UK pensions in Italy
    This article is published on: 2nd October 2020

    02.10.20

    There is nothing like a cold snap to focus the mind and it certainly arrived with a bang this year. In Rome we lost about 20 degrees of temperature in a week. However, I have to confess that I am rather glad that the autumn months are now upon us because the prolonged hot temperatures play havoc with trying to be productive.

    In this article, as you will see, there are a number of shorter topics, but ones which I think are relevant for our lives in Italy. During the summer I have been scanning the financial papers and the ‘norme e tributi’ pages of Sole 24 Ore to see what might affect our lives in the future. Fortunately, the Italian government seemed to give us a break this year and I didn’t find much of significant interest. However, a number of other matters have arisen in the last few weeks

    UK pensions and tax when living in Italy

    Let’s start with one of the more interesting matters that arose during the summer. I was contacted by a client who was enquiring about taking money out of her QROPS pension (a QROPS is a UK pension that has been moved away from the UK but still operates like a UK pension – useful when living abroad!).

    I have always advised my clients that any withdrawals from a UK personal pension are taxed at income tax rates in Italy, but over the last few years I have come across a number of clients whose commercialista has been declaring the pension as a ‘previdenza complementare’. This is the Italian equivalent of a UK personal pension. The main reason for choosing this route seemed to be a preferential flat tax rate of 15%. My argument has always been that the 2 structures have fundamentally different characteristics and therefore a UK personal pension should be considered an irrevocable trust, hence withdrawals are subject to income tax. In fact as far back as June 2018 I wrote the following in an article:

    I have heard stories from various people over the years that their commercialisti declare their UK pensions as ‘previdenza complementare‘, which loosely translated means complementary pension. However, the definition does not accurately complete the story. The reason for declaring it in this manner is that it is taxed at a preferential tax rate of 15%.

    I must admit here that I don’t think is the correct way of declaring income from an overseas pension / retirement plan. The ‘previdenza complementare‘ is a vehicle used in Italy to complement the pension which is offered through Italian social security (INPS). You may argue that this has the same purpose as that of an overseas pension fund. However, this is where the similarities end.

    In the case of a UK pension fund your contributions would attract tax relief during the accumulation phase. In the ‘previdenza complementare‘ (PC) the fund is taxable during the accumulation phase. The UK scheme is also not linked to the state scheme in any way and you can withdraw money from age 55 (personal pension) or scheme retirement age (occupational pension). The PC is linked to the Italian state retirement age. Lastly, since the contributions into a UK fund are paid gross into the plan, then the income is instead taxed on the way out, at the normal rates. The Italian PC has a preferential rate of taxation starting at 15% and reducing to 9% depending on how many years you have been contributing to the fund, because it is taxed during the accumulation phase. In short there are some distinct differences which lead me to believe that declaring a pension fund / retirement fund (which is a trust) as a ‘previdenza complementare’ in Italy, is incorrect. If you are in doubt then speak with your commercialista.

    In a lot of cases I was informed that the commercialista had contacted the local Agenzia delle Entrate and they had confirmed that this is correct. So, who was I to challenge it? However, I still believed that it was incorrect. Of course, no-one challenged it because it also meant the difference between being paying a 15% flat tax rate on that income or progressive income tax rates starting from 23%.

    However, during the summer the client I referred to above contacted her commercialista, who did not accept this definition, but in fact presented an ‘interpello’ issued by the Agenzia delle Entrate (an interpello is basically an ‘opinion’ from the Agenzia delle Entrate on a specific case that is presented to them) from May 2020 regarding a UK personal pension holder.

    In the interpello (which you can find HEREthe interesting part starts on page 7) it indicates that a UK personal pension should not be considered a ‘previdenza complementare’, but should actually be subject to progressive tax rates in Italy. This is quite an eye-opener because if this is the case, then it flies against the information gained from various commercialisti.

    I should add here that the interpello is merely an indicative judgment in this particular case and is by no means a definitive decision for everyone holding a UK personal pension and resident in Italy. However, the fact that the AdE has gone to the trouble to write this gives us a pretty good idea into their thinking, should they choose to follow it up.

    final salary pension review

    What to do?
    So what should you do if your commercialista has advised you to declare your UK personal pension as a ‘previdenza complementare’ and you are now benefitting from the 15% flat tax rate? I would take the interpello to them and ask their opinion based on the new evidence. Or you may choose to do nothing. Whatever your choice or the advice from the commercialista, we are now a little more enlightened into the thoughts of the Agenzia delle Entrate on this topic.

    Brexit
    It is worth noting here that Brexit is almost upon us and whatever your opinion as to how the UK will exit, a messy unfriendly exit may bring a few matters to light. In particular, the interpello also states that pension funds which ‘could’ be deemed to qualify are those which conduct business cross border and meet the pension rules of both EU states in which they are operating. I don’t know of a UK personal pension provider that does this anyway, but the mere fact that the UK is in the EU may gloss over some of these finer points. But then, what will happen once the UK leaves the EU?

    Which leads nicely on to the next problem that Brits are now facing in Italy.

    Bank account closures for UK citizens living in the EU

    By now, I am sure you have read the headlines saying that a number of UK banks are contacting or have contacted their customers living in the EU to close down their UK banks accounts, potentially leaving them without a UK account. To date the main culprits are the Lloyds banking group, which includes Halifax and the Royal Bank of Scotland, Coutts and Barclays.

    I am afraid to say that the rumours are true and I know of a number of people who have been contacted already.

    The culprit, of course, is Brexit…

    Avoiding bank charges

    These banks have now had to weigh up the benefits of retaining bank account holders in the EU post Brexit, because once they out of the EU market place they will be forced to adhere to individual EU jurisdictional regulations, as well as UK regulations, if they want to continue to service clients in any EU state. Clearly, for a bank which has no intention of developing business in Italy (in our case), nor does it have a sufficiently large client base in Italy already, then they are going to need to look to close down activities in those jurisdictions to ensure they do not fall foul of the regulators.

    It is interesting that, in contrast, HSBC Bank has not decided to pull from its EU markets because it has sufficient activities which take place throughout the EU. I have also heard that Nationwide is also not pulling any activities just yet.

    For many clients this is going to be a very tough time, as you could lose a bank account in the UK when you may still have bills being paid, or you simply use it when you are in the UK. To make matters worse, because you are no longer a resident in the UK, you can no longer request an account from another UK banking group.

    Many of the groups will also offer their international bank account services, of which the majority are based in the Isle of Man. This is not a good idea because the Isle of Man is not in the UK, but is a UK dependant territory and is deemed a fiscal paradise. It is currently on the grey list of ‘could do better’ in global fiscal transparency with the EU. It is anyone’s guess what will happen after the UK leaves the EU, but it is certainly not beyond imagination that the EU will look to impose punitive tax measures for anyone holding accounts in UK offshore jurisdictions. Let’s not forget that it only came off the black list in 2015!

    So, without any other options perhaps one of the better solutions is to look at an Italian bank which can provide a GBP account. I have used Fineco for years, and recommend it to many clients. They offer a EUR current account linked to a GBP and USD account and transfers of cash between accounts are made at spot rate, with no fee. It might be a solution, but will be no consolation for losing your UK bank account. Once again, another downside of Brexit for those of us that have chosen to live in the EU.

    bank-vault

    Why you should never leave more than €100,000 (or currency equivalent) in your bank account

    Still on the subject of banking, does the sound of a bad bank sound appealing to you? A bank that is so bad that it can take all the bad from all the other banks and just keep it there and away from us all. It sounds like a great idea in theory.

    On the 25th September the EU had a consultation round table event with a number of European bank leaders, asset management groups and government officials to discuss the possibility of creating a European-wide ‘bad bank’ which would take all that bad debt (debt which cannot be paid back for one reason or another) and which is currently sat on the balance sheets of a lot of European banks, particularly Italian ones and other Southern European states. The idea being that this bad debt could be whisked away from the banks, freeing them up from the worry of having to manage this debt and giving them the liberty to start lending once again, supposedly to individuals and businesses which pose a better credit risk and would be more reliable at paying the debt back.

    So far so good. I would not argue at this point. It seems like a good idea to help stimulate economies especially after the COVID-19 crisis.

    But morally, should we accept this?

    This is the argument put forward by a number of EU functionaries who argue that the banks are, once again, getting another bail out at the cost of the taxpayer. You and I.

    To remedy this, the ‘Bank recovery and resolution directive’ (BRRD) has proposed that certain parties should also have to meet some of that cost as well as the EU/taxpayer. Those parties have been identified as the shareholders of the bank, holders of the banks bonds and lastly, the one that should interest us all: deposit holders with more than €100,000 or currency equivalent held in any banking group. Does this mean that the EU, to fund the COVID-19 crisis, could make a cash grab on deposit holders with more than €100,000 or currency equivalent in their accounts? At this point it is only a proposal, but I shall be watching this space carefully.

    Based on this news, there is probably no better time to look at your financial plans closely, especially if you are holding high levels of cash in any banks around Europe.

    NS&I slashes rates!

    You might be someone who has been investing in NS&I products in the UK as a diversifier to your other holdings, or maybe just someone who likes to ‘play it safe’ with your money.

    National Savings and Investments

    National Savings and Investments, NS&I, are backed by the UK government and due to the COVID-19 crisis, the government has now moved to slash rates on all national savings products to the point where you have to ask yourself, ‘are they worth it?’

    The rate on the Direct Saver account has been slashed from 1% interest per annum to just 0.15%. Income Bonds, which have for a long time been considered a best buy, have been slashed from 1% interest rate to just 0.01% pa.

    Not only that, but the average interest rate on Premium Bonds (with the chance to win the big prize) will fall from 1.4% to just 1% and the amount of prizes issued will be reduced significantly.

    If that is not enough, the Bank of England is also toying with the idea of introducing a negative base interest rate. If they apply that to the NS&I products, then you will be effectively paying the government to hold them.

    Time to consider alternatives to protect your capital?

    Digital Payments

    Cashback for cashless transactions

    Italy has been desperately trying to find ways for the people to start using digital forms of payment instead of cash so that the economy can become more fiscally transparent and they can raise more tax revenue.

    By the end of November we will have confirmation on the new push to drive people towards using digital methods of payments in Italy, even for small transactions, such a buying coffee at the bar. The Italian government has come up with an idea to incentivise the drive to digital forms of payment.

    Firstly, from next year the maximum spend on contactless forms of payment will rise from €30 to €50.

    In addition, they have dreamt up another seemingly difficult to navigate proposal for a refund of expenses paid by card payments. I will have a go at deciphering it here:

    1. You will get a 10% reimbursement on expenses paid up to a maximum spend of €3000 per annum (hence a tax refund of max €300 pa).

    2. But, to achieve this you must make a minimum of 50 transactions every 6 months (100 every year) and the €3000 is in fact split into a spend of a maximum of €1500 every 6 months. The idea being that you can’t just go and spend on something costing €1500 every 6 months or a series of high value items to reach the limit.

    To receive the refund you will need to register on the app and enter your codice fiscale, and your debit/credit card details.

    3. Not only are they offering cash back on transactions but they are discussing a ‘super cashback’ prize of €3000 for the first 100,000 people who reach the maximum number of digital transactions in a year, within the limits provided above.

    Certainly food for thought. Watch out for confirmation of these offers sometime before the end of November and then start registering to get your cashback. In theory it should be easy, but based on previous experience of Italian government initiatives I fear it may turn out to be more complicated than first glance.

    I hoped you have enjoyed this ‘return to normality’ article. I will be sending out more information in the coming weeks and months to keep you up to speed with the goings on in the financial world and how that might impact our lives in Italy.

    If any information from this article has interested you and you would like to get in contact, you can reach me on gareth.horsfall@spectrum-ifa.com or on cell phone 333 649 2356 by call, sms or whatsapp.

    Gareth Horsfall ezine

    Are we going to change?

    By Gareth Horsfall - Topics: Italy
    This article is published on: 25th June 2020

    25.06.20

    Any change, even a change for the better, is always accompanied by drawbacks and discomforts

    – Arnold Bennett –

    Will things change for the better post Covid 19?
    Nearly everyone I speak with at the moment keeps asking, will the world get better and will we care more for the world and each other as a result of Covid? Have we learned our lesson about sustainability, ecological damage and the lifestyles we lead?

    It’s a good question and not one I would like to put a bet one (I am afraid that I am a sceptic when it comes to human nature and don’t believe that many are inclined to change behaviour so easily). That being said I could be being proven wrong, because after speaking with some of our asset manager partners recently (Tilney, Rathbones, Jupiter, Janus Henderson, to name a few), they pointed out that there are some notable positive trends that are emerging from the lockdown during the Covid crisis. These trends could seriously affect the way we lead our lives and also hence how we invest our money and so are worth a mention here.

    I will touch on 4 trends which could have legs and are great dinner party conversation if you are bored of Covid talk and talk of house prices!

    Smart_working

    1.  Smart working 
    Let’s just get the pronunciation correct for Italy before we start.  It is ‘smat’ whirr-king’    Now that is out of the way, we can talk about the impact of smart-working on the workplace.

    The best way to explain this is to give the example of a friend in Rome.   Our kids go to school together and he works as a director at the energy company ENEL.   He was informed, not long after the lockdown, that smart working arrangements would become permanent with immediate effect and that from January 2021 they will impose a global 3 day smart working, 2 days in the office, working week.   This will apply to all global managerial staff.

    What is interesting about this is that ENEL are not alone in this decision.  There are numerous other large firms taking the same decision.  Enel have understood during lockdown that as a company they can perform all their normal activites online: conference calls, video meetings etc.    For the days in the office the work place will be arranged into a number of generic work stations with connection capabilities and which will have to be booked in advance to ensure a place on your work day.

    As a result of this ENEL are not going to renew 1500 contracts (which was to be expected!) but more interestingly they are going to be closing a significant amout of office space which will go onto the property/rental market.   With many other firms taking similar decisions, what is the impact going to be on the commercial and residential property market?  Could this lead to a surplus of property and push prices in cities down?  Equally, what about people working from home, is the space they have sufficient?  These thought leads nicely onto Trend No 2

    2.  Nesting 
    I always thought that nesting was the time when a young couple met, starting dating seriously and before long started making plans to buy a house, settle down and maybe think about planning a family.

    Nesting is now the termed also used for property owners who are looking to either sell up and move from a urban area to a rural one, or others who are looking to purchase a second home in a rural/countryside area.

    Data is coming out at the moment to show that the professional classes (who are the main beneficiaries of smart working) are taking steps to rethink their lives in light of the lockdown crisis.    In the USA and also the UK data is showing that there has been a surge in requests for information about countryside properties or periphery areas to live, equally homes in urban areas with a garden and/or near an outdoor space such woods or lakes.  In London, searches for houses with gardens are up 42% on last year.  Is this a long term trend or something that we will see more of?  At the moment it is likely to be a knee jerk reaction to the lockdown and is predominantly something that the professional classes have the fortune of being able to take advantage of, but it is not beyond imagination that this is a trend that is here to stay because, like my friend who works for ENEL who is also considering his current living arrangements (he will need an office space at home) alot of people who will now have the option to work from home, will want to do so in a non-polluted, potentially more creative space with perhaps contact with nature or at a minimum another room in the house which they can turn into a work space.

    And it’s not just the property market that this could affect because if the trend could affect the provision of public services and utilities.  Things like health services, schools and also the distribution of retail outlets as a way of servicing more spread populations may need to be rethought.  It would present some real challenges but create some great opportuntities as well.   What will be interesting is to see how bailout money from the EU is allocated and what, if any, conditions are attached to it because the talk is that significant demands will be made for EU states to invest in green infrastructure, show significant contribution to climate change goals and the provision of health services to citizens everywhere, to be eligible for Covid 19 bailout money.

    Interestingly, in Italy, I saw a news article a week or so ago with a Sindaco in Umbria who said that he was looking to get funding to get the medeival town connected up to high speed internet, with the idea to re-populate the area with younger professionals who want to work from more beautiful places and not be confined to cities.  I have been saying the same things for years.   Without high speed internet connection the most beautiful towns, cities and villages in Italy are going to be inhospitable to anyone, not just the younger generation.  To reverse the brain drain first you need to provide high speed internet connection to your citizens.    High speed internet has become a utility just like gas, water, and electricity.    So, let’s hope they manage to do something about it and attract human capital away from the cities and back into more creative and beautiful parts of the country.

    family dinner

    3.  The return of the family meal 
    This is a nice new trend for whoever yearns for the old days of sitting around the family meal table and enjoying quiet time together.  Apparently during the quarantena the habit was on the increase and the latest research is showing that families who had traditionally not eaten together because of professional parents returning home at different times in the evening, or otherwise being busy, were being forced together and taking advantage of this time to immerse themselves in the culture of the traditonal family meal.

    What might this mean in terms of changing trends?  Well, it appears that during the lockdown, those same people who were returning to the family dinner table, were also purchasing more expensive food and more of it.   (I can attest to this because, I also thought that since we were locked at home with no way of escape, then we should at least eat well).  If people eat at home more frequently and can enjoy family meals more frequently, then might they be more inclined to buy more expensive food, but also more expensive wine? and more of it? That may also mean that people also demand more takeaway / delivery services (think Deliveroo, Just Eat, Glovo etc).  And lastly what kind of long lasting impact could it have on the hospitality sector, restaurants and hotels?.

    These are trends which money managers are watching closely, less because of the habit itself, but more the reaction of big food and drinks firms.    To give you an example the big drinks firms Diageo has carried out a survey and found that 80% of its sales are for use in the home, not for consumption in bars etc.   This may come as no surprise but it does beg the question for a firm like Diageo – why are they selling through third party channels like supermarkets and other distribution channels when most people today are used to receiving deliveries at home?  Could they cut costs by selling directly?   This brings me to point No 4 and a story about everyone’s favourite sportswear compnay Nike.

    4.  Cutting out the middleman
    During the lockdown, I like many other people, watched quite a bit more Netflix than I am accustomed to.   One of the series which I watched and thoroughly enjoyed was ‘The Last Dance’, a documentary about Micheal Jordan and the story of the Chicago Bulls during their record breaking 6 times NBL championship wins.   A great one to watch if only to watch the acrobatic magnificence of Micheal Jordan in his prime.   Why am I mentioning this?

    Nike created the line ‘Jordan’ on the back of the sporting genius of Micheal Jordan and it has been a success ever since.  What has been notable is that that the brand’ Nike Jordan’ during his time at the top was built on the back of traditional advertising/marketing and retail outlets.  But times have changed.   Now, younger people are communicating through different social media channels, the latest being TickTock, and these are changing consumer patterns of behaviour.   People are less inclined to spend their time trawling retail outlets to try and find that special pair of Nike trainers when they can see their sporting heroes wearing them on videos and also order them easily with a few clicks on their phone.

    So this brought Nike to a change in strategy a few years ago.    A focus towards selling more directly to clients, and in much the same way as the revolution with food and drinks manufacturers as I explained above, Nike have been experimenting with direct consumer channels for years and are looking to expand this.

    By direct consumer channels I mean selling directly from their own website and/or from a Nike store.   Nike stores in themselves are an interesting experience.  There are a number in Rome and I went into one about a year ago.  They are a less a store, but more of an experience.  This experience feeds into their brand and message around ‘Just do it’.   It is very impressive and in this way they don’t dliute their brand or their profits through 3rd party distribution channels.

    This trend which Nike has been developing for years now, is a trend which we could see grow after Covid as shopping habits change even more.   As an example I know a couple in Rome in their 50’s who had never used Amazon before the lockdown because they thought it was unsafe.   During lockdown they decided to sign up and use it.  They are hooked and cannot believe how easy it is and how much choice they have.    We already know that retail is being revolutionised but this could take it further.

    Can we imagine a future where we have one login for all retail outlets, supermarkets etc, and when we order from any one of them a delivery is made to a locker installed in or near our home that deliveries which can be accessed with a secure code.   A Utopian (or Dystopian future?).

    If just a 20% shift is created in consumer behaviour as a result of this crisis, a 20% in the way we live and work, this could create an equally tectonic shift in the corporate sector and the way they engage with us.   For our money it will create opportunties and also there will be failures.  More importantly we are likely to see an even greater shift to companies who have a strong focus on the enviornment, social protections and good governance of their companies.

    More than ever our money managers need to be on top of a changing world.  Thankfully they are.

    If you would like to have a health check on your money for the future,
    then you can get in touch by contacting me on
    gareth.horsfall@spectrum-ifa.com
    or call/whatsapp on +39 333 649 2356

    Getting residency in Italy before Brexit

    By Gareth Horsfall - Topics: BREXIT, Italy, Residency
    This article is published on: 16th June 2020

    16.06.20

    In this E-zine I am going to provide anyone who is still wondering about residency in Italy, before Brexit, with a quick, hassle-free guide how to obtain it.

    I was hoping that I could try and avoid the ‘B’ word again in my lifetime, but alas we are not quite there yet and a number of people have contacted me in the last two weeks to ask about the process of getting residency in Italy before Brexit day arrives (currently 31st Dec 2020, although I have my suspicions it might be extended again – watch this space!).

    You may know that the process of getting residency in Italy once the UK leaves the EU will get considerably more complicated. If you are unconvinced then ask an American resident in Italy, they should be able to tell you! Therefore, if you are a British citizen and thinking of making the move to Italy, and are in a position to do it now, then you may want to consider applying before Brexit day to simplify your life. Equally, I know there are many people who are living in Italy but are procrastinating about taking residency. This will act as a useful guide for anyone still sitting on the fence and feel free to share it where you see fit.

    Before I give an explanation of the things to watch out for, here is a summary of the much more complicated process of elective residency, if you choose to do so POST Brexit

    ***This guide is mainly for people who are choosing to move and sustain themselves economically, i.e. retired individuals or those living from savings. It is not relevant for anyone considering self/employment in Italy. Different rules may apply in those cases***

    Post Brexit (non EU citizen) elective residency application process

    Step 1: Make an appointment at the Italian Consulate in your home country – this can takes months!

    Step 2: At this appointment you need to complete a request for a visa granting you a right to live in Italy for more than three months in any six month period. You will be required to submit information on where you intend to stay (a property or rental, and evidence of specific accommodation), proof of your ability to support yourself financially, with evidence of income of at least €31000pa per single person or €38000pa for a couple, although this may be flexible depending on a) who you are speaking with and b) which region of Italy you may be moving to. You will also be required to prove that you have sufficient private health insurance cover and will not be a burden on the Italian health care system. The visa will be granted within 90 days of application being submitted.

    Step 3: Once you receive the visa and make your move to Italy, within eight days you will need to make your request for a Permesso di Soggiorno (right to stay). This can be obtained from the post office. This process can take weeks, even months to issue and you will be informed that you need to go to your local Questura once it is granted, to pick up the certificate. The permission will normally be issued on a one or two year renewable basis for five years, after which time you can apply for a long term permission.

    This is a very brief overview of the procedure, but as you may have understood, the process from start to finish is likely to take months, possibly years, and will probably need a lot more planning to make the move. In addition, there are much higher minimum income and savings requirements. However, as things stand you can still apply as a EU member state citizen until 31st December 2020 and most of the EU member benefits will carry forward after Brexit provided that the application is submitted before Brexit date.

    Residenza Italy

    The NO-HASSLE guide to getting residency in Italy before Brexit

    So let’s examine the process of attaining residency as things currently stand and see why, if it is possible for you, it might be better to try to get residency before Brexit.

    Going along to the comune/municipio office and requesting residency is a relatively easy process, but can be cumbersome if you are not prepared (it took me five visits to the Municipio in Rome to receive my residenza). You will inevitably run into people who have formed opinions about Brexit already and may refuse your application on the basis of the UK having left the EU already. This is incorrect and you would do well to go armed with the Italian ministry circular which says as much. You can find that document HERE. There are a few simple things you need to provide, but they may deem your evidence unsatisfactory for their requirement. Knowing the pitfalls of each criteria can be the difference between multiple failed visits to make the residency request or one successful visit.

    The three basic items which you will require (apart from identification) are:

    1. Evidence of sufficient economic resources to stay in Italy
    2. Evidence of health insurance to cover at least the first year in Italy
    3. Evidence of a place to stay

    Whilst these three items might seem at first glance to be relatively simple to provide, there are some idiosyncrasies that trip people up and which can cause delays. Given that time is no longer a luxury then knowing the details could help. So, let’s deal with each one in turn.

    • 1. Evidence of sufficient economic resources to remain in the country

      The first thing to understand is that this requirement is governed by regional authorities and is very much at the discretion of local services as to whether they will accept you in their comune or not based on your evidence of income, savings, pensions etc. Rome or Milan, for example, will have very strict rules and will adhere to them rigidly. A small comune in Abruzzo, for example, might be more relaxed as they are happy to have an influx of foreign money into the area. However, it is worth checking with your local comune first to see if they have any minimum income levels for which they would need to see evidence. At the time of writing, the minimum income requirement for the Roma Capitale comune is €5.824,91pa and they would typically expect to see approximately €10,000 in savings as an emergency reserve. However, these figures can be subject to interpretation depending on who you are speaking with on any particular day! So be prepared.

      Make sure you take both the original and copies of any documents with you to any meetings, including bank statements showing regular income payments, or pension statements demonstrating the amount of money you have in the fund and any regular income payments from it. Additionally, if you have any savings and/or investments then take recent statements along as well.

      Remember to only present documentation that you are asked for, so as not to open a can of worms which could generate requests for additional documentation.

    • 2. Evidence of health insurance to cover at least the first year in Italy

      This factor seems to be the one that trips most people up when making an application for residency and it comes as no surprise. The EU requirements for a change of residence clearly state that when transferring EU member state, you must have sufficient health cover provision to not be a burden on the health care system. (If you are employed then this doesn’t apply as you will be automatically enrolled in the health care system when paying social security contributions.)

      The confusion derives from the following factors:

      i) That all EU citizens have an emergency health card which would cover you for travel within the EU area. This is correct. In Italy it is known as the TEAM card and is link to the tessera sanitaria and in the UK it is called the EHIC. However, this card only provides temporary emergency cover for medical care during visits as a tourist in the EU area and not any longer term protection. Therefore, making an application for long term residency cannot, by definition, be covered by a short term medical provision agreement.

      ii) Another assumption is that once you are resident in Italy you can apply to make a voluntary contribution to the health care system to receive full medical care (see document HERE). This is correct and the price is relatively cost effective depending on your annual total income. However, here is where a classic Catch 22 exists. You cannot register for and pay for healthcare in Italy until you have residency and you cannot have residency until you can demonstrate that you have adequate medical insurance cover in place. Therefore, an interim arrangement is needed as per point iii) below:

      iii) It is assumed that a health care insurance needs to be a full provision medical insurance policy, e.g. Bupa. This is not the case and could cost thousands for full medical care benefits which are not needed for the purposes of making a residency application. In fact, we need to refer, once again, to the EU rules regarding residency. The rules state that if you are not working and have sufficient economic resources to live on then you need to provide yourself with the equivalent S1 reciprocal agreement on healthcare for retired member state citizens, until such time as you are eligible for the S1 or have alternative arrangements, e.g. annual voluntary payment into the Italian health service.

      To resolve this you need to take an insurance policy on a one year renewable basis, which is acceptable for the purposes of obtaining residency and that can be cancelled from the second year in the case that you can make the application for the annual voluntary payment.

      Speak with a good insurance agent and ask for cover for the codes: E106, E109, E120 and E121. These are the specific codes which need to be covered for insurance purposes. However, it would be sensible to ask the insurance agent to check with your local comune in the case that they have additional regional or local provisions that they would also want to cover. My advice has always been to stick to one of the main insurance companies in Italy rather than going through smaller companies. The main players would be Generali, Zurich, Allianz, Groupama and UnipolSai, as examples. A policy of this nature may cost a few hundred instead of a few thousand depending on your age and pre-existing health conditions.

    • My tips for a better residency application

      In addition to the above, here are a couple of tips which you might find useful.

      An email pec
      You might be thinking, what is an email pec? It actually stands for Posta Elettronica Certificata and I find it is one of the most useful things to have in Italy. A few years ago the government introduced legislation to allow electronic communication between individuals and municipal offices/agencies, police and also companies. However, they rightly had suspicions about the efficacy of traditional email channels because of the inability to confirm the identity of the individual sending the email. Enter: pec email.

      Pec email is an email account that can be opened for about €30pa with a lot of service providers and during the opening process you are required to provide identification (copy of passport and/or ID card) to clear a security check. Once passed, the account is opened and you will be able to communicate freely with most official offices. Any email you send is certified as having been sent from you, but in addition you receive a receipt when the email has been received and accepted by the receiving party.

      This is useful in many ways, but specifically with regards to residency it does mean that you can submit an application to your comune by sending all the necessary information via the pec email. (Check the comune website for their specific email pec to which you can send documents). For instance, if you are unable to return to Italy, for whatever reason, and want to submit your application before Brexit date, then it can be done via pec email.

      Residency applications will be backdated to the date which you officially submitted the application (with correct documentation), so for any applications submitted by pec, or in person, before Brexit date, but then formally approved afterwards, you ‘should’ be granted residency from the moment of application.

      You will also find an email pec useful if you have to submit documentation to the police, other government agencies and even some companies. For the cost of approx €30pa I think it’s worth it, although responses to your emails will be few and far between and any follow up may need to be done in person or on the phone. Expect to do some follow-up!

    italy tax

    The best tax day of the year 2020
    July 5th

    A little known point about residency and tax, in Italy, is reference to the 183 day rule.

    This rule states that if you are considered resident in Italy for less than 183 days per annum, then you are not considered tax resident in the country for the full tax year (different rules apply to employed persons). So, for calendar year 2020, if you take residency after the 5th July then you are assured to be considered non resident for the full tax (calendar) year and your first taxable year will be 2021.

    This might be important for anyone who is thinking of applying now, but might like to remain tax resident elsewhere for the year 2020.

    It will not affect your ability to get residency in Italy in 2020, but it will merely mean that your taxable year of residency will not start until 2021.

    A useful piece of information if you need to look at your financial arrangements and how you can streamline and simplify them to make them more tax effective for life in Italy. The transition year is always the most important because of the ability to use cross border financial planning opportunities to their fullest.

    And that, in brief, is your no-stress guide to to obtain residency in Italy as an EU citizen. However, whilst I write the words ‘no-stress’, they don’t correspond with my experience of municipal offices in Italy, or indeed the experience of many others. Always expect the unexpected.

    I wish you or anyone you know all the best of luck making an application for residency in Italy, pre-Brexit, and who knows, we may even be in for an extension again. My guess would be at the witching hour on Dec 23rd so as not to ruin Christmas too much for the retailers and companies that will suffer most from a hard Brexit. Non vedo l’ora!