专家表示,意大利计划对离境的富裕外国居民征收高额税收,这是一项有害的“自损”举措,并让英国人感到“受惊”。
Plans to impose a hefty tax on wealthy foreign residents who leave Italy are a damaging own goal and have “spooked” Britons, experts say.
财务顾问警告称,希望逃避工党政府推出的税收的富裕英国人,如果移居意大利,将是“跳出火坑,落进火窟”。
Rich Britons looking to escape taxes introduced by the Labour Government would be “jumping out of the frying pan and into the fire” if they moved to Italy, financial consultants warned.
乔治亚·梅洛尼政府因推行一项吸引数千名富裕外国人定居意大利的单一税率制度而获得国际赞誉。
Giorgia Meloni’s government won international plaudits for a flat-tax regime that lured thousands of wealthy foreigners to settle in Italy.
尤其是米兰,外籍人士在那里购买房产、加入私人俱乐部、在高档餐厅消费,并将子女送入昂贵的私立学校。
Milan in particular saw expats buying property, joining private clubs, spending in high-end restaurants and enrolling their children in expensive private schools.
但出人意料的是,这个保守派联盟政府提议对在意大利定居后后来决定迁走的外籍人士征收26%的资本利得税。
But in a surprise move, the conservative coalition has proposed levying a 26 per cent capital gains tax on expatriates who, having settled in Italy, later decide to relocate.
该措施在该国最新预算中宣布,适用于资产达到80万欧元(70万英镑)或以上,且在过去10年中至少有6年是意大利税务居民的外国人。专家表示,外籍人士希望在六年期限届满前离开该国。
The measure, announced in the country’s latest budget, would apply to foreigners with assets of €800,000 (£700,000) or more who have been tax residents in Italy for at least six of the 10 preceding years. Expats would want to escape the country before the six-year period was up, experts said.
财务顾问告诉《每日电讯报》,这项“离境税”让原本计划移居意大利的富裕英国人感到“受惊”。
The exit tax has “spooked” wealthy Britons who were planning to move to Italy, financial consultants told The Telegraph.
“这是一件奇怪的事。人们会盯着时钟,确保自己停留时间少于六年,”伦敦税务和咨询公司摩斯金斯顿史密斯的税务主管蒂姆·斯托沃尔德说。
“It’s an odd thing to do. People will be watching the clock, making sure they stay for less than six years,” said Tim Stovold, head of tax at Moore Kingston Smith, a tax and advisory firm based in London.
“通常,意大利、西班牙和葡萄牙等国家的这些低税率制度旨在吸引人们长期定居。他们向经济注入资金。”
“Normally these low tax regimes in countries like Italy, Spain and Portugal are designed to attract people to settle long term. They pump money into the economy.
“我在意大利有客户购买房产、开展修复项目,并成为村里的主要雇主。这对东道国来说是巨大的利好。”意大利自由市场智库布鲁诺·莱奥尼研究所表示,政府的这一举措令人费解。该研究所称,退出税给政府带来的收入微薄,却会阻碍富有外国人在意大利投资。
“I have clients in Italy who buy property, embark on a restoration project and become the principal employers in the village. It’s a terrific benefit to the host country.”The Istituto Bruno Leoni, an Italian free-market think tank, said the government initiative was incomprehensible. It said the exit tax would bring in only modest revenue for the government but would dissuade wealthy foreigners from investing in Italy.
该研究所补充道:“一方面,我们试图通过统一税制吸引外国人;另一方面,我们却告诉他们,一旦定居下来,如果想离开,就必须支付不成比例的税务义务。”
“On the one hand, we are trying to attract foreigners with the flat-tax regime. On the other hand, we are telling them once they settle, if they want to leave, they have to pay a disproportionate tax duty,” it added.
意大利的统一税制是在2017年由前一届政府推出的。最初,搬迁至意大利的外国人需缴纳的年度统一税为10万欧元。梅洛尼政府将其提高至20万欧元,随后又提高至30万欧元,部分原因是为了填补政府财政,部分原因是意大利民众对米兰等城市房价上涨的反弹。即使有此提高,该安排对许多富有外国人仍具吸引力。
Italy’s flat-tax regime was introduced under a previous government in 2017. Initially, the annual flat tax to be paid by foreigners who relocated to Italy was €100,000. The Meloni government increased it to €200,000 and then to €300,000, in part to fill government funds and in part because of a backlash among Italians over rising property prices in cities such as Milan. Even with that increase, the deal remained appealing to many wealthy foreigners.
斯托沃尔德先生表示:“假设你以2000万英镑出售了企业,该安排依然具有吸引力——你只需缴纳30万欧元的税款。”“现在想要摆脱英国税制的人将面临的问题是,这是否属于‘跳出油锅落入火坑’的情况。”
“If you sold your business for £20m, say, the arrangement remained attractive – you would only pay €300,000 in tax,” said Mr Stovold. “What will now trouble people who want to leave the UK tax regime is the question of whether it’s a case of ‘out of the frying pan and into the fire’.
“在英国你需缴纳24%的资本利得税,而在意大利,你现在将面临26%的退出税。这似乎是一个乌龙球,一种自损行为,类似于英国废除非定居税制。”
“You would pay 24 per cent capital gains tax in the UK but now, in Italy, you will pay a 26 per cent exit tax. It appears to be an own goal, an act of self-harm, similar to when the UK abolished the non-domiciled regime.
“对于想要离开英国的人来说,我认为这会让意大利在他们的意向目的地名单中大幅靠后。”去年4月,英国政府决定废除“非定居”税制,该制度此前免除英国居民中拥有外国定居地者的海外收入纳税义务,包括遗产税方面。
“For people looking to leave the UK, I think this moves Italy a long way down the list of where they will want to go.”In April last year, the British Government decided to abolish the “non-dom” tax regime that exempted the overseas income of UK residents with a foreign domicile from taxation, including for inheritance purposes.
意大利的离境税对父母来说将尤为棘手,因为他们希望让孩子在学校安稳就读六年以上。
The Italian exit tax will be particularly problematic for parents, who will want to settle their children in school for more than six years.
“它将阻碍那些想要离开英国、在意大利定居的人,”斯托沃尔德说。
“It will be a deterrent for people who were looking to leave the UK and live in Italy,” said Mr Stovold.
米什康·德雷亚律师事务所私人财富与税务主管查理·索斯纳表示,已经移居意大利的富裕外国人此前已因统一税门槛的大幅上调而感到不安。
Wealthy foreigners who had moved to Italy had already been unsettled by the steep increase in the flat tax threshold, said Charlie Sosna, head of private wealth and tax at the law firm Mishcon de Reya.
“移居意大利的人带着一种对税制稳定性及其是否会变化的犹豫,特别是当他们一夜之间将统一费用翻倍时,”他说。
“Those who have moved to Italy went with an element of hesitation over the stability of the tax regime and whether it would change, particularly when they doubled the flat fee cost overnight,” he said.
“宣布征收离境税可能会让已经移居那里的人非常担忧。意大利最好尽快就适用范围给出明确说明,特别是已经处于统一费用制度下的人是否会被排除在外。”他说,拟议的离境税将损害意大利作为高净值人士避风港的形象。
“The announcement of an exit tax is likely to cause considerable concern to those who have moved there. Italy would be wise to give clarity very soon as to the scope and, in particular, whether those under the flat fee regime [already] there will be excluded from it.”The proposed exit tax will damage Italy’s image as a haven for high-net-worth individuals, he said.
“这让他们受到了惊吓,客户很可能会观望事态发展,以及这对他们可能意味着什么,”索斯纳先生说。该拟议法律尚未在意大利议会讨论,仍可能进行修正。
“This will have spooked them and clients are likely to wait and see how this develops and what it may mean for them,” said Mr Sosna. The proposed law is yet to be discussed in Italy’s parliament, and could still be subject to amendments.
“我们还不了解所有细节,但似乎它只适用于2027年1月1日后开始在意大利取得居留身份的人,”斯托沃尔德说。“所以已经在该国的人可能没事。”四年前当选的梅洛尼被认为给意大利带来了难得的政治和经济稳定时期,此前几十年来意大利一直是“走马灯式”总理更迭、高债务和不可预测的代名词。
“We don’t know all the details, but it seems that it will only apply to people whose residency in Italy begins after Jan 1, 2027,” said Mr Stovold. “So those who are already in the country are probably OK.”Ms Meloni, who was elected four years ago, has been credited with bringing a rare period of political and economic stability to Italy, which for decades was a byword for revolving-door prime ministers, high debt and unpredictability.
在离境税被提出之前,英国移民咨询公司亨利·帕特纳斯将意大利描述为“欧洲市场上高净值个人和家庭寻求财政确定性并结合欧盟准入的主要替代目标地”。
Before the exit tax was mooted, Henley & Partners, a British migration consultancy, described Italy as “a principal alternative destination within the European market for high-net-worth individuals and families seeking fiscal certainty combined with EU access”.
被问及拟议中的新财富税的影响,该公司表示将“在立法最终确定前”保留判断。该公司称,新税项的影响仍不明确。
Asked about the impact of the proposed new wealth tax, the company said it would reserve judgment “until the legislation is finalised”. The implications of the new levy were still unclear, the firm said.
作为二战后任期最长的意大利总理,梅洛尼女士明年将面临大选。民意调查显示,她领导的执政联盟与中左翼政党联盟势均力敌。
Ms Meloni, the longest-serving Italian prime minister since the Second World War, faces a general election next year. Opinion polls suggest that her governing coalition is running neck and neck with an alliance of centre-Left parties.