After years of questionnaires, audits and interpretative doubts, Revenue Agency Resolution No. 60 of Dec. 9, 2024, finally clarified that the mere transfer of foreign currency to a current account having the same currency and in the name of the same person does not generate taxable matter.

We were stuck with clarifications provided by a 1998 ministerial circular, however voluntary disclosure and subsequent verification activities had brought to light a not insignificant regulatory (rectius interpretive) problem, especially in a financial context where diversification, including currency, is quite common.