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UNCERTAINTY CONCERNING TAX REGULARIZATION OF BELATED INCOME
thursday, 11th june 2015

While the third round of tax regularization ended on the 1st January 2014 when the “Point de contact régularisation” of the Tax ruling service closed its doors, there are many taxpayers that still wish to regularize their tax situation, in particular concerning the obligation to declare life insurances that have been subscribed abroad.

On the 29th January 2015, the Special Tax Inspection (ISI) diffused an internal instruction “related to the taxation of income declared after the deadline”. It therefore allows latecomer taxpayers to spontaneously declare their revenues that need to be regularized and specifies how the ISI must tax these incomes.

If the Council of State cancels the circular, all the agreements concluded under the terms of the text will be null, the decision being retroactive. Agreements concluded with the administration from that day onwards will be consequently carried out without any legal certainty.

It is therefore advisable to be attentive to the forthcoming ruling by the Council of State.