• Sectors we work in banner(2)

    Quick Reads

New Italian guidelines on taxation of trusts

On 20 October 2022, the Italian Revenue Agency issued the Circular Letter No. 34/E laying down the final version of the guidelines concerning the taxation of trusts (“the Guidelines”). A draft version of the guidelines was published in August 2021 for public consultation. The Guidelines are expected to have a significant impact for clients and intermediaries. The subjects addressed include the following:

  1. Income tax treatment of beneficiaries of non-resident transparent trusts (i.e., trusts where the beneficiary has a right to the income);
  2. Income tax treatment of trust distributions made by non-resident non-disregarded trusts;
  3. Inheritance and gift tax treatment of trusts in the light of the case law of the Supreme Court;
  4. Impact of the disregarded characterisation of a trust for income tax and inheritance and gift tax purposes;
  5. Reporting obligations of resident beneficiaries over the assets held in non-resident trusts;
  6. Wealth tax treatment of resident trusts.

The Guidelines can be found here.

More detailed commentary will follow.

Our thinking

  • IBA Annual Conference 2024

    Charlotte Ford

    Events

  • Wills for Brits in Switzerland (or with assets here)

    Michael Wells-Greco

    Insights

  • DIFC Courts Release 2023 Annual Report

    Peter Smith

    Quick Reads

  • The Telegraph quotes Sophie Dworetzsky on plans to scrap the non-dom tax status

    Sophie Dworetzsky

    In the Press

  • I Want to Relocate to Switzerland - what do I need to know?

    Grégoire Uldry

    Insights

  • Wealth Management in Qatar

    Alim Khamis FCIArb

    Insights

  • The Rights of Beneficiaries: Access to Trust Information

    Samantha Ruston

    Insights

  • The UK’s March 2024 Budget: how the proposed new tax rules will work for US-connected clients

    Sangna Chauhan

    Insights

  • The UK’s March 2024 budget: Offshore trusts - have reports of their demise been greatly exaggerated?

    Sophie Dworetzsky

    Insights

  • Playing with FYR: planning opportunities offered by the UK’s proposed four-year regime for newcomers to the UK

    Catrin Harrison

    Insights

  • James Broadhurst writes for the Financial Times’ Your Questions column on inheriting company shares

    James Broadhurst

    In the Press

  • Regime change: The beginning of the end of the remittance basis

    Dominic Lawrance

    Insights

  • IFA Magazine quotes Julia Cox on the possibility of more tax cuts before the general election

    Julia Cox

    In the Press

  • eprivateclient quotes Sally Ashford on considerations around power of attorney

    Sally Ashford

    In the Press

  • Computer says No - my prediction of UK border chaos on Wednesday 1 January 2025

    Paul McCarthy

    Quick Reads

  • Cosmopolitan quotes Sarah Jane Boon on how to deal with break-up admin

    Sarah Jane Boon

    In the Press

  • The Financial Times, The Guardian and City AM quote Sophie Dworetzsky and Dominic Lawrance on Labour’s proposed tax crackdown on non-doms

    Sophie Dworetzsky

    In the Press

  • Why Switzerland is poised to become a prime jurisdiction for families to establish their private trust companies

    Dharshi Wijetunga

    Insights

  • Update on delinked payments

    Jessica Jolleys

    Quick Reads

  • London’s Knowledge Clusters: From Emerging to Maturing – Start Ups on the Global Stage?

    Lynsey Inglis

    Quick Reads

Back to top