The RW Schedule is the instrument through which taxpayers resident in Italy must disclose investments and financial assets held abroad — including indirectly — and calculate the patrimonial taxes IVIE, IVAFE and, from 2024 onwards, the tax on the value of crypto-assets.
This obligation applies not only to individual taxpayers, but also to non-commercial entities, simple partnerships (società semplici) and persons considered “beneficial owners” of assets held abroad. The objective is to ensure transparency and traceability of foreign wealth, thereby preventing tax evasion and upholding the fairness of the tax system.
1. Persons Required to File
The following are required to complete the RW Schedule:
- natural persons fiscally resident in Italy;
- non-commercial entities and simple partnerships resident in Italy;
- beneficial owners within the meaning of anti-money laundering legislation.
The obligation covers:
- patrimonial investments abroad (real property, registered movable assets, works of art, etc.);
- foreign financial assets (shareholdings, current accounts, securities, foreign insurance policies, stock options, etc.);
- crypto-assets, including those held via digital wallets not associated with third parties.
The obligation also applies in cases of indirect holding through foreign fiduciaries, trusts, foundations or interposed persons, as well as where operational mandates exist over foreign accounts (save for purely representative powers, for instance those held by company directors).
2. Exemptions from Monitoring
No monitoring obligation arises:
- for foreign current accounts with a maximum aggregate value below €15,000 during the year (save for IVAFE purposes);
- for foreign financial assets entrusted to Italian resident intermediaries that apply withholding taxes or substitute taxes;
- for certain categories of workers abroad, including:
- public and international employees whose residence is established by law;
- cross-border workers, provided they dispose of their foreign assets within six months of ceasing to work abroad.
Please note: even where an exemption from monitoring applies, the obligation to declare foreign income received remains in force.
3. Crypto-Assets: Patrimonial Tax and Reporting Obligations
From 1 January 2024, crypto-assets are subject to:
- a RW monitoring obligation, if held outside the circuit of resident intermediaries;
- a patrimonial tax of 2 per mille, to be paid in accordance with the procedures applicable to income taxes.
The taxable base is determined by:
- the value as at 31 December recorded on the exchange;
- in the absence of such a value, by available market data or, as a last resort, by the acquisition cost.
In the event of disposal during the year, the value at the date of exit is taken into account. Where joint ownership exists, the tax is calculated on the basis of the ownership share and the number of days of holding.
A tax credit is recognised for patrimonial taxes paid abroad on similar crypto-assets.
4. Valuation of Assets
Separate criteria apply to the valuation of investments and financial assets:
a) Real Property
- EU/EEA: cadastral value; in the absence thereof, acquisition cost; otherwise, market value;
- non-EU: cost as resulting from deeds or, in the absence, market value as at 31 December or at the end of the holding period;
- succession/donation: declared value or, in the absence, the cost of the deceased/donor.
b) Non-Real Patrimonial Assets
- Acquisition cost or market value at the beginning and end of the period.
c) Financial Assets
- Market value as at 31 December (or at the end of the holding period);
- In the absence thereof: nominal or redemption value;
- For unlisted instruments: statement from the foreign intermediary or appropriate documentation.
Where multiple instruments of the same category are involved, the LIFO (Last In, First Out) method applies.
5. Filing Procedures
The RW Schedule must also be completed:
- if the assets were disposed of during the year;
- in the event of changes affecting at least one foreign property, indicating all properties held.
If the taxpayer is subject only to the monitoring obligation and not to patrimonial taxes, the columns relating to IVIE/IVAFE need not be completed.
Where joint ownership or co-ownership exists, each holder must complete a separate RW line, indicating the full value of the asset and their respective ownership share.
Conclusion
The RW Schedule is one of the most complex obligations within the income tax return. The extension of reporting requirements to crypto-assets and beneficial owners strengthens international fiscal transparency, but demands from taxpayers a precise review of their assets. Correct valuation and the clear distinction between the monitoring obligation and the tax liability are essential to avoid errors and penalties.
Practical Summary Table – RW Schedule: Who Must File and When
| Type of asset or activity | Example | RW obligation | Tax due (IVIE / IVAFE / crypto) | Notes |
|---|---|---|---|---|
| Foreign current account with average annual balance of €12,000 | Account in Germany for personal savings | NO | NO | Excluded if below threshold, save for IVAFE |
| Foreign current account with average annual balance of €18,000 | Deposit account in Switzerland | YES | IVAFE (2‰) | Monitoring obligation and tax apply |
| Property in Spain used as a holiday home | Apartment in Barcelona | YES | IVIE (0.76‰) | Obligation even without income produced |
| Shareholding in a foreign company | 20% stake in an English Ltd | YES | NO | Even if no profits are distributed |
| Foreign life insurance policy not managed by an Italian intermediary | Contract with a Luxembourg company | YES | IVAFE (2‰) | Only where no substitute tax has been applied |
| Cryptocurrencies in a private wallet | BTC on Ledger | YES | Crypto tax (2‰) | Value as at 31/12 or at end of holding period |
| Cryptocurrencies on a foreign exchange without a resident intermediary | ETH on Binance | YES | Crypto tax (2‰) | Even if below €15,000 |
| Foreign asset held through a Swiss fiduciary | Fiduciary interest in a Luxembourg company | YES | Depends on asset type | Beneficial owner status is relevant |
| Joint ownership of a foreign account | Two siblings, balance €20,000 | YES (both) | IVAFE for each on a pro-rata basis | Each declares the full value with their ownership percentage |
| Foreign assets in a trust | Real property or assets in a US trust | YES | IVIE/IVAFE where applicable | If one qualifies as beneficial owner |