- The line is owed by a resident individual holding foreign investments, foreign financial assets or crypto-assets — and by the beneficial owner behind an account in somebody else's name.
- The €15,000 exemption is narrower than its reputation. It covers deposits and current accounts only, and it is measured on the highest balance reached at any moment in the year, so one payment passing through breaks it for the whole year.
- The penalty is 3 to 15 per cent of the undeclared amount, once per return, and nothing in it depends on the tax. On €50,000 that is €1,500 to €7,500 beside €34.20 of tax.
- The same comma keeps a flat €258 where the declaration is filed within ninety days of the deadline. That is 3 per cent of €8,600 — below the balance at which the obligation can first arise — so it is the cheaper route everywhere it applies.
- A holding in a privileged-regime state is charged on a doubled band, 6 to 30 per cent, and the balance itself is presumed to be income withheld from tax unless its holder shows otherwise.
A designer moves from Lisbon to Milan, becomes resident, and leaves €50,000 in the bank she has had since university. Italy taxes that account €34.20 a year. It fines her at least €1,500 — and up to €7,500 — for not naming it on the return, which is close to 44 times the tax she would have paid by naming it.12
The two numbers come from two different laws with two different bases. The tax is charged on the wrapper: a foreign current account owes a fixed amount whatever is in it, which is priced in full elsewhere. The penalty is charged on the money.
The €15,000 line, and what it leaves out
The obligation itself is one sentence. An individual resident in Italy who, during the tax year, holds foreign investments, foreign financial assets or crypto-assets “suscettibili di produrre redditi imponibili in Italia” must set them out in the annual return. It reaches the person who is not the holder but the beneficial owner, in the anti-money-laundering sense of that term, so an account in a relative’s name is inside it.3
There is a threshold, and it is narrower than its reputation. The obligation falls away for foreign deposits and current accounts “il cui valore massimo complessivo raggiunto nel corso del periodo d’imposta non sia superiore a 15.000 euro” — the highest figure reached at any moment in the year, not the balance on 31 December and not the average. One payment that lands and leaves in March breaks it for the whole year. And it is a sentence about bank accounts: a brokerage account, a fund holding or a wallet of crypto is reportable from the first euro.4
| What you hold abroad | Off the form? | On what condition |
|---|---|---|
| A deposit or current account | Yes, up to a point | only if the highest aggregate balance reached all year stays at or under €15,000 |
| Shares, funds, bonds, policies | No | the threshold sentence names deposits and current accounts, and nothing else |
| Crypto-assets | No | written into the obligation itself, with no threshold anywhere in the article |
| A property abroad, unchanged all year | Yes | only while nothing about it changes, and the tax on it is owed either way |
| Assets held through an Italian intermediary | Yes | only where that intermediary has already withheld the tax on the income |
| Anything above, held through someone else | No | the obligation follows the beneficial owner, not the name on the account |
D.L. 167/1990 art. 4, commi 1 and 3, consolidated text in force to 31 December 2026, read sentence by sentence.346
The fine is charged on the money, not on the tax
Most Italian tax penalties are a share of tax that went unpaid. This one is not. The omission is punished “con la sanzione amministrativa pecuniaria dal 3 al 15 per cento dell’ammontare degli importi non dichiarati” — a share of the holding. Whether any tax was due, and how much, does not enter the calculation.1
That is why the two numbers pull apart as the balance grows. The tax on a current account does not move: it is €34.20 at €20,000 and €34.20 at €500,000. The minimum penalty is €600 at the first and €15,000 at the second. Held as investments rather than cash the tax is a percentage too, and the ratio then settles into a constant: three per cent against two per mille means the smallest fine is fifteen times the year’s tax at any size of holding, and the largest seventy-five times.52
Three per cent of the balance — the minimum in D.L. 167/1990 art. 5 comma 2 — at five balances, per annual return. The tax on the same account is €34.20 at every one of them, which at this scale is a bar about one pixel high at the left of the chart and invisible at the right.15
The band runs per return, so a holding left out for three years is three violations. The first euro over the threshold is where it starts: at a highest balance of €15,001 the minimum is €450.03, against nothing at all one euro lower.5
The statute keeps its own cheap route
The same comma ends with a flat figure: where the declaration is filed within ninety days of the deadline, €258. Nothing in it depends on the balance, and that has an arithmetic consequence the two sentences never state together. €258 is three per cent of €8,600 — below the €15,000 at which the obligation can first arise. So the flat fee is cheaper than the percentage everywhere the percentage can apply, by a margin that widens with every euro held.15
Put right voluntarily, all of these come down by the fractions in the penalties act — to a ninth or a tenth of the minimum inside ninety days, an eighth by the following year’s return, a seventh after that. Which of the two ninety-day limbs applies to a missing foreign holding is a question about whether it is an error in a return or the omission of a declaration of its own, and the statute supports both readings, so both are priced below. The ladder itself, and the ninety-day line that governs the return as a whole, are set out in the piece on filing late.7
| How it ends | Cost | Where it comes from |
|---|---|---|
| Filed within ninety days of the deadline, reduced to a tenth | €25.80 | art. 5 comma 2 read with art. 13 comma 1 lett. c) |
| Filed within ninety days, reduced to a ninth | €28.67 | art. 5 comma 2 read with art. 13 comma 1 lett. a-bis) |
| Later, put right before the next return is due | €187.50 | an eighth of the minimum, art. 13 comma 1 lett. b) |
| Later still, put right voluntarily | €214.29 | a seventh of the minimum, art. 13 comma 1 lett. b-bis) |
| Filed within ninety days, unreduced | €258 | art. 5 comma 2, third sentence |
| Found by the Agenzia, charged at the minimum | €1,500 | 3% of the amount, art. 5 comma 2 |
| Found by the Agenzia, charged at the maximum | €7,500 | 15% of the amount, art. 5 comma 2 |
Statutory rates and fractions applied to a €50,000 balance: D.L. 167/1990 art. 5 comma 2 for the 3–15% band and the €258 ninety-day figure, D.Lgs. 472/1997 art. 13 comma 1 for the reductions a voluntary regularisation pays.175
The spread across that table is the whole decision. €25.80 and €7,500 punish the same omission of the same account; what separates them is when it was dealt with and by whom. The order is not the calendar’s: at this balance the two reduced later routes come to less than the ninety-day figure paid in full, because one is a fraction of three per cent of €50,000 and the other is a flat sum. For the 2025 return, filed in 2026, that ninety-day window runs from the 31 October filing deadline into late January.59
Where it doubles, and where the balance becomes income
A holding in one of the states on Italy’s two 1999 and 2001 privileged-regime lists is charged on a doubled band, six to thirty per cent: €3,000 to €15,000 on the same €50,000.1
For those states a second provision goes further than a penalty. Assets held there in breach of the reporting duty “si presumono costituite, salva la prova contraria, mediante redditi sottratti a tassazione” — the balance is treated as untaxed income unless the holder shows otherwise — with the penalties for an unfaithful return doubled and the assessment deadlines doubled with them. That turns a reporting failure into an income assessment, and it is not priced here: what it costs depends on the year the money is attributed to and on what the holder can document about where it came from.8
What an unnamed foreign holding costs, by balance (CSV)Fifteen balances from €5,000 to €1,000,000, each with the tax due on both wrappers, the ordinary and privileged-state penalty bands, the ninety-day figure, the reduced amounts a voluntary regularisation pays, and the resulting multiple of the year's tax. A second file carries the scope table above.What this does not settle
The statute charges a share of “gli importi non dichiarati” and does not define which value that is. Every figure here treats it as the balance the missing line would have carried, which is the reading the wording supports and not a measurement of how offices apply it. Nor is it a prediction of where inside a 3-to-15 band a particular case lands: the minimum is used throughout because it is the floor the text guarantees, and the general rules on combining and reducing penalties are not modelled.
One interaction is worth naming because it cuts against the threshold. The same section of the return that carries the reporting line is also where the tax on foreign assets is settled, so an account below the €15,000 line can still bring its holder back to the form for the tax. The obligation the threshold lifts is the reporting one; guidance reconciling the two could not be read for this piece, so it is left as a question rather than answered.
Both articles quoted here stop on 31 December 2026. The reporting duty is repealed from 1 January 2027 by the 2026 decree consolidating assessment law, and the penalty by the 2024 sanctions testo unico as amended at the end of 2025. Their replacements live in annexes that could not be fetched here, so nothing in this piece speaks to what the band becomes. What it prices is the text that governs the return now due.1011
None of this is advice about what to file. It is what the rules in force charge for a line that is there and a line that is not.
Sources
- 1.Normattiva — D.L. 167/1990, art. 5, comma 2 (testo in vigore dal 4 settembre 2013 al 31 dicembre 2026): la violazione dell'obbligo di dichiarazione dell'art. 4, comma 1, è punita «con la sanzione amministrativa pecuniaria dal 3 al 15 per cento dell'ammontare degli importi non dichiarati», dal 6 al 30 per cento per gli Stati a regime fiscale privilegiato, e «nel caso in cui la dichiarazione … sia presentata entro novanta giorni dal termine, si applica la sanzione di euro 258»
- 2.Normattiva — D.L. 201/2011, art. 19, commi 18–22 (IVAFE: 2 per mille sui prodotti finanziari, imposta fissa sui conti correnti, 4 per mille sugli Stati a regime privilegiato, credito per imposta patrimoniale estera)
- 3.Normattiva — D.L. 167/1990, art. 4 (obbligo di indicare nel quadro RW della dichiarazione annuale gli investimenti e le attività finanziarie detenuti all'estero)
- 4.Normattiva — D.L. 167/1990, art. 4, comma 3 (testo in vigore al 31 dicembre 2026): l'obbligo di indicazione non sussiste «per i depositi e conti correnti bancari costituiti all'estero il cui valore massimo complessivo raggiunto nel corso del periodo d'imposta non sia superiore a 15.000 euro»
- 5.TaxCompass dataset — what an undeclared foreign holding costs, by balance: the tax due on each wrapper, the ordinary and privileged-state penalty bands, the ninety-day figure and the reduced amounts a voluntary regularisation pays (CSV)
- 6.TaxCompass dataset — which foreign holdings escape the annual reporting line and on what condition, read sentence by sentence from D.L. 167/1990 art. 4 (CSV)
- 7.Normattiva — D.Lgs. 472/1997, art. 13 (ravvedimento, testo in vigore al 31 dicembre 2026): sanzione ridotta a un decimo entro trenta giorni, un nono entro novanta, un ottavo entro il termine della dichiarazione, un settimo oltre; interessi al tasso legale giorno per giorno
- 8.Normattiva — D.L. 78/2009, art. 12, commi 2 e 2-bis (testo in vigore al 31 dicembre 2026): gli investimenti e le attività finanziarie detenuti negli Stati a regime fiscale privilegiato in violazione dell'art. 4 del D.L. 167/1990 «si presumono costituite, salva la prova contraria, mediante redditi sottratti a tassazione», con raddoppio delle sanzioni dell'art. 1 del D.Lgs. 471/1997 e dei termini di accertamento
- 9.Normattiva — D.P.R. 322/1998, art. 2 (testo in vigore al 1º settembre 2026): dichiarazione delle persone fisiche «in via telematica tra il 15 aprile e il 31 ottobre dell'anno successivo»; comma 7, le dichiarazioni presentate entro novanta giorni sono valide e quelle presentate «con ritardo superiore a novanta giorni si considerano omesse»; comma 9, i termini che scadono di sabato sono prorogati al primo giorno feriale successivo
- 10.Normattiva — D.L. 167/1990, art. 4, testo in vigore dal 1° gennaio 2027: «ARTICOLO ABROGATO DAL D.LGS. 5 AGOSTO 2026, N. 141»
- 11.Normattiva — D.L. 167/1990, art. 5, testo in vigore dal 1° gennaio 2027: «ARTICOLO ABROGATO DAL D.LGS. 5 NOVEMBRE 2024, N. 173 COME MODIFICATO DAL D.L. 31 DICEMBRE 2025, N. 200»
Every external figure above links to the document it came from. Datasets we produced are downloadable, so the arithmetic is checkable rather than taken on trust.
- €7,800Splitting a firm's profit can cost two partners €7,800the most that dividing a professional firm's profit differently can change its two partners' income tax
- €50,000Have your partita IVA cancelled, and the next one needs a €50,000 suretyof surety, for three years, before a cancelled taxpayer may hold an Italian partita IVA again
- €1,160The same €36,000 through a platform, and a €1,160 gap in Italian taxless take-home on the same €36,000, when a platform's commission sits inside the flat tax's revenue box
- €2,779Sell the same €40,000 to EU consumers and keep €2,779 lessless take-home on the same €40,000, once the buyers are consumers in another member state
- €17,100Move to Italy, and your home account owes €34.20 a year — your investments, 0.2% of everythingthe foreign balance where Italy's yearly tax on investments overtakes the flat €34.20 it charges on a bank account
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