This possibility came out as a result of some statements made by the Government organs to the press; several comments and assumptions followed.

From an ethical point of view, this possibility certainly does not send a strong sign to dishonest taxpayers with respect to the firmness of the State’s behaviour.

However, there is already the active repentance remedy (“ravvedimento operoso”) for mistakes made by taxpayers; this aspect and the cash needs - aiming at hindering the application of safeguard clauses automatically provided by the European treaties, lead to have to accept a  solution similar to the one adopted at the time of the tax shelter.

The assumptions reported by the press talk about terms entailing higher costs for taxpayers to adopt this remedy i.e. voluntary disclosure of offshore assets and financial instruments that have never been declared. This raises serious doubts as to whether people - who created cash and funds abroad from not so honest activities (disregarding tax evasion) - will apply for this procedure that, unlike what happened with the tax shelter, exposes them directly to an assessment of their incomes and wrongdoings by the Italian Tax Authority.    

It will be therefore be quite likely that professional firms will succeed in convincing some more reluctant taxpayers to adopt this form of regularisation, disregarding the fact that it will be quite burdensome, but having as counterpart the tranquillity to be able to use legitimately what they had hidden from the Tax authorities, once they have paid the related taxes and sanctions.

At this point, I ask myself, whether it would be wise to turn this regime into something ordinary as it happens already with the active repentance. It is actually quite unlikely that this possible second round of voluntary disclosure will eliminate the problem of non declared funds held abroad by Italian citizens.

As a consequence, ethics would suffer from this further relief granted by the State, but on the other hand the State’s need for cash can be solved or at least reduced without having to further hit the honest citizens.