With Ruling n. 165 issued on August 8, 2024, the Italian Tax Administration ruled on a matter in which a trust was terminated by mutual agreement of the settlor, trustees, and current beneficiaries. The trust had been organized under the laws of Jersey as an irrevocable trust. Jersey law allowed a beneficiary to permanently renounce
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Italys’ Register of Trusts In Effect, First Filing Due By December 11, 2023
On October 9, 2023, the last Ministerial Decree required for the final implementation of Italy’s Register of Trusts was published, and the Register of Trusts is now in effect. The initial filing deadline is December 11, 2023. The filing in the Register is required for domestic trusts, private foundations, and similar legal arrangements, defined as
Italys’ Register of Trusts In Effect, First Filing Due By December 11, 2023
On October 9, 2023, the last Ministerial Decree required for the final implementation of Italy’s Register of Trusts was published, and the Register of Trusts is now in effect. The initial filing deadline is December 11, 2023. The filing in the Register is required for domestic trusts, private foundations, and similar legal arrangements, defined as
Italy plans to repeal special tax regime for new resident workers, professional and entrepreneurs from 2024
On October 16, the Council of Ministers approved a legislative proposal that will repeal the special tax regime for new resident workers, entrepreneurs, and professionals with effect from January 1, 2024.
The special regime, enacted in its final form in 2020, allows Italian and foreign nationals who establish their tax residence in Italy while not
Is There a Change of Course On Split Tax Residence Year? Italian Tax Agency Rules That Italy-Switzerland Tax Treaty’s Part-Year Tax Resident Provision Prevails Over Domestic Law, Refers to OECD Commentary In Support
In its ruling n. 370 issued on July 4, 2023, the Italian Tax Agency concluded that in a case of a change of tax residency during the year, the treaty provision according to which the change of tax residence takes effect on the day of the transfer out of Italy to the foreign country is
Is There a Change of Course On Split Tax Residence Year? Italian Tax Agency Rules That Italy-Switzerland Tax Treaty’s Part-Year Tax Resident Provision Prevails Over Domestic Law, Refers to OECD Commentary In Support
In its ruling n. 370 issued on July 4, 2023, the Italian Tax Agency concluded that in a case of a change of tax residency during the year, the treaty provision according to which the change of tax residence takes effect on the day of the transfer out of Italy to the foreign country is
Italian Taxation of Trusts: U.S. Complex Trust Meets Italy’s Anti-Abuse Rule, Distributions of Trust Income to Italian Trust Beneficiaries Not Taxable In Italy
The Italian Tax Agency’s Ruling n. 309 of April 28, 2023 (Risposta-n.-309_2023-1.pdf) deals with the issue of taxation to Italian beneficiaries of income distributions from a U.S. trust.
Background.
Under Italy’s tax law, trusts with identified income beneficiaries are treated as fiscally transparent, and the beneficiaries are taxed on their share of the
Italian Taxation of Trusts: U.S. Complex Trust Meets Italy’s Anti-Abuse Rule, Distributions of Trust Income to Italian Trust Beneficiaries Not Taxable In Italy
The Italian Tax Agency’s Ruling n. 309 of April 28, 2023 (Risposta-n.-309_2023-1.pdf) deals with the issue of taxation to Italian beneficiaries of income distributions from a U.S. trust.
Background.
Under Italy’s tax law, trusts with identified income beneficiaries are treated as fiscally transparent, and the beneficiaries are taxed on their share of the
Italian Taxation of Trusts: Tax Agency Rules that Settlor’s Unconditioned Power To Remove and Replace Guardian Makes the Trust Fiscally Interposed, Nonexistent For Tax Purposes
In its ruling no. 267, dated March 27, 2023 (Risposta-n.-267_2023.pdf), the Italian Tax Agency addressed a case involving a trust where the Settlor reserved the power to revoke and replace the Guardian and retained certain powers related to the shares of a company he transferred to the trust, including the power to appoint
Italian Taxation of Trusts: Tax Agency Rules that Settlor’s Unconditioned Power To Remove and Replace Guardian Makes the Trust Fiscally Interposed, Nonexistent For Tax Purposes
In its ruling no. 267, dated March 27, 2023 (Risposta-n.-267_2023.pdf), the Italian Tax Agency addressed a case involving a trust where the Settlor reserved the power to revoke and replace the Guardian and retained certain powers related to the shares of a company he transferred to the trust, including the power to appoint