SAN MARINO – The meeting between the San Marino trade unions, the president of the CSIR and the Italian Deputy Minister of Economy and Finance took place on 18 September Maurizio Leopromoted by the Secretary of State for Finance Marco Gattion the tax dispute concerning retired former cross-border workers.
At the center of the discussion are the disputes initiated by the Emilia-Romagna Revenue Agency against pensioners resident in San Marino. The trade union organizations reiterated their position according to which the interpretation adopted by the Italian tax authorities on the taxation of pensions would be unfounded, recalling some rulings of the Court of Cassation on the meaning of the term “social security” provided for by the Convention between San Marino and Italy.
During the meeting, the functioning of the San Marino pension system was also discussed, which provides public support to guarantee adequate pension levels even for medium-low incomes. According to the trade unions, this element must be considered in the comparison on the taxing power, without prejudice to the principle according to which taxes must be paid in only one State.
Also on the table is the Italian request to modify the Convention by introducing the principle of concurrent taxation, with the possible equalization of taxes in Italy and the recognition of the tax credit for the amount already paid to San Marino. The trade union organizations also underlined that currently, for INPS pensions paid to San Marino residents, a withholding tax is not applied at source, where required.
The San Marino Government has also put forward proposals for revising the Convention. According to what was reported by CSdL, CDLS and USL, both Executives have announced the launch of specific technical tables shortly to seek a shared solution. “The positions did not appear to be ironclad, not even with regard to the possibility of identifying alternative solutions to competing taxation”, report the trade unions, evaluating this opening positively.
The president of the CSIR reiterated the request for a solution favorable to former cross-border pensioners, recalling what was provided by the Italian State for those who worked in Switzerland and in the Principality of Monaco. For trade union organizations, the right to tax credit also remains intact.
During the meeting, a moratorium on tax bills was also requested until the discussion between the two countries is concluded. The request is motivated by the fact that the people affected by the disputes relating to the 2019 tax returns subsequently received requests for the following years as well, while other pensioners were involved in the meantime.
The trade union organizations therefore believe it is necessary to accompany the start of negotiations with measures that allow them to manage the period necessary to reach an agreement, in particular for those who have already paid taxes in both states.
CSdL, CDLS and USL finally thanked the Secretary of State for Foreign Affairs Luca Beccarithe Senator Sunday Spinelli and the Ambassador Fabrizio Colaceci for their involvement in the affair.
