Skip to content Postal savings bonds: exemption for non-residents only with continuous residence in white-list countries
With Reply No. 148 of 2026, the Italian Revenue Agency clarified that interest arising from postal savings bonds received by a non-resident person may benefit from the exemption from the 12.5% substitute tax provided that, for the entire period in which the securities were held, the holder was resident in States included in the white list and the bonds are deposited with Poste Italiane. The exemption may also apply where the holder transfers residence between different white-list countries.
The Italian Revenue Agency has provided clarifications on the tax treatment of interest arising from postal savings bonds received by a person who is not resident in Italy. In particular, the tax authorities clarified that the exemption from substitute tax may also apply where the holder of the bonds has transferred their residence from one State to another, provided that both States were included, during the relevant periods, in the list of countries that allow an adequate exchange of information with Italy.
The case
The Applicant is an Italian citizen resident in Switzerland who holds postal savings bonds issued on 4 October 2014 and maturing on 4 October 2026.
The taxpayer, who has not been resident in Italy since the bonds were issued, asks whether the interest accrued on the bonds must also be subject to taxation in Italy upon redemption and what documentation must be submitted to Poste Italiane in order to benefit from any applicable exemption, thereby avoiding subsequent refund procedures due to double taxation.
Tax treatment 14 of postal savings bonds
Pursuant to Article 23 of the Italian Income Tax Code (TUIR), investment income paid by the State, resident entities or permanent establishments located in Italy is deemed to arise in Italy and is, as a general rule, taxable also when received by non-resident persons.
Specifically, interest and other proceeds arising from postal savings bonds placed by Poste Italiane on behalf of Cassa Depositi e Prestiti are ordinarily subject to a 12.5% substitute tax on income, pursuant to Legislative Decree No. 239 of 1 April 1996.
However, the same decree provides for an exemption regime for interest received by persons resident in States and territories that allow an adequate exchange of information with Italy and are included in the so-called white list referred to in the Ministerial Decree of 4 September 1996.
The requirement of continuous residence in white-list countries
To benefit from the exemption, the condition of residence in a white-list country must be met for the entire period during which the beneficiary is the registered holder of the postal savings bonds.
The exemption regime therefore requires continuous entitlement to the exemption from the date on which the security was issued. Two different tax regimes cannot be applied to postal savings bonds during the period in which they are held.
Where the holder has transferred their residence between several States, it is therefore necessary to verify that, for each relevant period, the State of residence was included in the white list.
Required documentation
For the exemption to apply, the postal savings bonds must be deposited with Poste Italiane S.p.A.
The taxpayer must also demonstrate their tax residence in a white-list State for the entire period in which the securities were held. For this purpose, Poste Italiane may obtain:
a certificate issued by the competent tax authorities of the country of residence; or, alternatively, a self-certification signed by the beneficial owner or their legal representative, prepared using the form approved by Ministerial Decree of 12 December 2001.
The documentation may also be submitted at the time of payment, provided that it expressly certifies that the conditions required for the exemption did not change throughout the period in which the taxpayer was the holder of the bonds. Where residence was transferred between different States, the documentation must cover each country in which the beneficiary had their tax residence.
The Italian Revenue Agency’s reply
The Italian Revenue Agency acknowledged that the taxpayer may benefit from the non-application of substitute tax on interest, premiums and other proceeds arising from the postal savings bonds, provided that the securities are deposited with Poste Italiane and that the information concerning foreign residence is duly substantiated.
In the case examined, the taxpayer was resident in Germany on the date the bonds were issued and subsequently in Switzerland, after Switzerland was added to the white list in 2016.
Therefore, since the taxpayer was resident, for the entire period in which the securities were held, in States included in the white list, they may benefit from the exemption from the Italian substitute tax.
It remains understood that the tax authorities may verify the taxpayer’s actual tax residence and the fulfilment of the applicable requirements during an audit.