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Black List Countries 2024: the Revenue Agency's list of tax havens

Which countries are on the Black List and identified as tax havens for Italy? The Revenue Agency provides the updated list for 2024 of all those nations in which a privileged tax regime (very low or zero) is in force.
The countries on the Revenue Agency's blacklist not only provide for easier taxation than the Italian one but do not allow an exchange of tax information with other countries.
Currently the only list of Italian tax havens serves only as a burden of proof for the change of residence of natural persons (citizens and not businesses, companies or companies) who have emigrated to one of these countries.
The numerous revisions made over the years to the legislation regarding the Black List have reshaped and upset the initial list foreseen, with many countries able to withdraw from the list thanks to the automatic exchange of information at an international level and the signing of bilateral agreements against double taxation .
There are, however, countries that still do not collaborate on these rules for the fight against international tax evasion and avoidance and these are precisely the nations that, even today, are present on the Black List.
The most common definition of the countries included in the Black List corresponds to tax havens.
The nations identified as such are part of a specific list published by the Revenue Agency.
The most interested parties are all those who have active relationships with operators having residence or domicile in one of the countries on the complete list.
Below we will indicate which countries are included in the Revenue Agency's Black List, with reference to the exact circular from the body dependent on the Ministry of Economy.
We will then explain what tax havens are, illustrating any tax obligations for those who operate with the latter.
Black List countries 2024: the list of tax havens What are the countries in the Revenue Agency's Black List Black List, new for 2024 The Revenue Agency's Black List Why is the Revenue Agency's Black List no longer updated What are the tax havens included in the Revenue Agency's Black List The tax havens in the European Union's Black List Which are the countries in the Revenue Agency's Black List The old list drawn up annually by the Revenue Agency has been replaced by a community list which has become, in fact, the point of reference for identifying states with privileged taxation.
Starting from 2017, in Italy, the obligation to communicate for transactions carried out with countries on the Black List has been abolished, even if the list still remains in force (only formally).
Currently the list includes 12 states, the list is now updated based on ministerial decrees that dictate the rules for those who operate with residents in these countries.
For the Revenue Agency's Black List, reference should be made to the list of tax havens of the European Council which includes 12 non-cooperative states for tax purposes: Guam; Palau; Panama; Fiji United States Virgin Islands; Bahamas; Eel; Turks and Coicos Islands; Samoa American Samoa Trinidad and Tobago; Vanuatu.
As far as the Revenue Agency is concerned, however, the latest list of countries in the Black List are contained in circular number 39 of 26 September 2016 and are: Andorra; Bahamas; Barbados; Barbuda; Brunei; Djibouti; Grenada; Guatemala; Cook Islands; Marshall Islands; US Virgin Islands; Kiribati; Lebanon; Liberia; Liechtenstein; Macau; Maldives; Nauru; Niue; New Caledonia; Oman; French Polynesia; Saint Kitts and Nevis; Solomon; Samoa; Saint Lucia; Saint Vincent and the Grenadines; St.
Helena; Sark; Seychelles; Tonga; Tuvalu; Vanuatu.
Since then, however, the list has no longer been updated by the Revenue Agency and, therefore, to identify the Black List countries it is necessary to refer to the aforementioned EU list.
For Italy, in addition to the 12 countries mentioned, other countries are also included in the Black List but with the limitation to some sectors and activities.
These countries are: Bahrain: "with the exclusion of companies carrying out exploration, extraction and refining activities in the oil sector"; Monaco: "with the exclusion of companies that generate at least 25% of their turnover outside the Principality".
The list described above, however, also includes activities and companies in particular that are based in certain countries.
This further classification includes another 12 countries whose names and related activities we report: Angola, with reference to oil companies that have obtained exemption from the Oil Income Tax, to companies that enjoy tax exemptions or reductions in sectors fundamentals of the Angolan economy and for investments envisaged by the Foreign Investment Code; Antigua, with reference to international business companies, carrying out their activities outside the territory of Antigua, such as those referred to in the International Business Corporation Act, n.
28 of 1982 and subsequent amendments and additions, as well as with reference to companies that produce authorized products, such as those referred to in local law no.
18 of 1975 and subsequent amendments and additions; Dominica, with reference to international companies carrying out activities abroad; Ecuador, with reference to companies operating in Free Trade Zones that benefit from income tax exemption; Jamaica, with reference to export production companies that benefit from the tax benefits of the Export Industry Encourage Act and companies located in the territories identified by the Jamaica Export Free Zone Act; Kenya, with reference to companies established in the Export Processing Zones; Panama, with reference to companies whose revenues flow from foreign sources, according to the legislation of Panama, to companies located in the Colon Free Zone and to companies operating in the Export Processing Zones; Puerto Rico, with reference to companies carrying out banking activities and companies provided for by the Puerto Rico Tax Incentives Act of 1988 or by the Puerto Rico Tourist Development Act of 1993; Switzerland, with reference to companies not subject to cantonal and municipal taxes, such as holding, auxiliary and "domiciled" companies; Uruguay, with reference to companies carrying out banking activities and holding companies that exclusively carry out offshore activities.
Black List, new for 2024.
The decree of the Ministry of Economy and Services of last 20 July, published in the Official Gazette 175 of 28 July 2023, provides that Switzerland officially leaves the Black List.
From 2024, therefore, Switzerland is no longer considered a Tax Haven given that the convention between Rome and Bern on cross-border workers is implemented.
What will Switzerland's removal from the blacklist mean for taxpayers? There will no longer be a doubling of the penalties for violating the tax monitoring obligation and the doubling of the assessment deadlines will also cease (10 years to carry out tax checks).
The Revenue Agency's Black List From a purely geographical point of view, the tax havens included by the Revenue Agency until 2016 mainly belonged to the Caribbean region.
Along with Antigua and Barbadua, there were the Bahamas, Dominica, Jamaica, Puerto Rico, Grenada, the US Virgin Islands, Saint Kitts and Nevis, Saint Lucia and Saint Vincent and the Grenadines.
The other largest representation came from the islands of the Pacific Ocean, which registered one more country than the Caribbean region alone.
The list included the Cook Islands, Marshall Islands, Kiribati, Nauru, Niue, New Caledonia, French Polynesia, Solomon Islands, Samoa, Tonga, Tuvalu and Vanuatu.
Africa also figured heavily in the list with five nations.
In fact, the states of Angola, Djibouti, Kenya, Liberia and Seychelles were included.
Asia competed with Bahrain, Lebanon and Oman in the Middle East, while representing the rest of the Asian continent were Brunei, Macau and the Maldives.
Nor should the role of the nations of Central and South America (3 in total) be underestimated: Ecuador, Panama and Uruguay.
Finally the Old Continent: in addition to the Channel Islands and Sark, the spotlight was on Andorra, Liechtenstein, Monaco and Switzerland.
Why the Revenue Agency's Black List is no longer updated Formally, the Revenue Agency's Black List is not updated to the latest current year because it was superseded by the tax decree connected to the Budget Law for 2017, which provided for “the repeal of black list communications”.
Until 2001, however, annual communication to the Revenue Agency was mandatory if the transactions carried out with companies resident or domiciled in tax havens exceeded the sum of ten thousand euros.
The amendment presented before the approval of the text relating to the tax decree received the green pass from the Budget and Finance Commission of the Chamber of Deputies.
Originally, therefore, the Revenue Agency's list was indispensable to allow interested parties to comply with the tax provisions established by law.
Since communication is no longer mandatory, there is no longer even a need for the body dependent on the Ministry of Economy and Finance to update the Black List.
Consequently, the last list present in Circular 39 of September 2016 is preceded by the following sentence: "The table below summarizes the situation of the countries indicated in the Ministerial Decree of 23 January 2002, in force on 31 December 2015".
The final update therefore dates back to the end of 2015.
What are the tax havens included in the Revenue Agency's Black List Tax havens are states with privileged tax regimes.
In the nations mentioned above, the taxes to be paid are significantly lower than the average overall sum paid by citizens living in countries not included in the Black List.
Furthermore, they do not provide for the exchange of tax data with other states.
It is important to underline that tax havens have a very negative impact on a state's fiscal budget.
For a more in-depth reading, we refer you to the specific guide on how tax havens work.
Tax havens on the European Union Black List The European Union Black List is made up of 12 jurisdictions: Guam; Palau; Panama; Fiji United States Virgin Islands; Bahamas; Eel; Turks and Coicos Islands; Samoa American Samoa Trinidad and Tobago; Vanuatu.
The objective that the European Union sets itself with the list of tax havens is to achieve greater transparency and better governance, as well as combating tax evasion and overcoming the fragmentation of the lists drawn up at national level.

Author: A.W.M.

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