The Generational Shield: Succession Planning and Italian Real Estate
The Macroeconomic Context of Global Wealth Preservation
The architecture of global wealth preservation is currently undergoing a profound, structurally irreversible metamorphosis. For the ultra-high-net-worth individual, the historical certainties of capital retention have been decisively shattered by a wave of confiscatory legislative reforms sweeping across the Anglophone world. The sovereign state, seeking to plug gaping fiscal deficits and address domestic political pressures regarding wealth inequality, has increasingly turned its attention to the intergenerational transfer of assets. This paradigm shift has transformed succession planning from a matter of passive administration into a critical theater of defensive financial strategy. In this volatile environment of shrinking safe harbors and aggressive wealth extraction, the Italian Republic has paradoxically emerged as the preeminent sanctuary for international capital. Despite its historical reputation for labyrinthine bureaucratic complexity and high aggregate tax burdens on domestic labor, Italy offers arguably the most aggressive and impenetrable tax arbitrage in Western Europe for the transfer of dynastic wealth. At the exact nexus of this fiscal architecture lies prime Italian real estate, an asset class that transcends mere aesthetic or lifestyle utility to function as the ultimate generational shield. Through a highly specific combination of historically low statutory valuations, extraordinarily favorable inheritance tax rates, and a recently fortified legislative framework concerning trusts and lifetime gifts, Italian trophy assets represent an unparalleled vehicle for the frictionless transfer of capital across time.
To fully grasp the magnitude of the Italian arbitrage opportunity, one must approach the subject not as a traditional real estate transaction, but as a complex mathematical optimization problem within the field of international taxation. The preservation of capital over multiple generations is mathematically impossible in a jurisdiction that periodically extracts thirty to forty percent of an estate's aggregate value. Compound interest, the traditional engine of wealth creation, is entirely neutralized when the principal is subjected to such severe cyclical haircuts. Therefore, the primary objective of the family office or the sophisticated individual investor is jurisdictional arbitrage: the legal relocation of assets and tax residency to an environment that mathematically permits the continuous compounding of capital without sovereign interruption. The Italian legal framework, specifically its regime for inheritance and gift taxes applied to immovable property, provides exactly this mathematical certainty. By divorcing the taxable base of an asset from its commercial market value and applying minimal, highly compartmentalized tax rates to that suppressed base, the Italian state effectively subsidizes the intergenerational retention of wealth. This essay will rigorously dissect the mechanics of this arbitrage, contrasting the increasingly hostile environments of the United Kingdom and the United States with the modernized, highly efficient structures now codified in Italian law.
The Italian Succession Framework: The Architecture of Capital Retention
In stark, deliberate, and highly structured contrast to the confiscatory Anglophone jurisdictions, the Italian Republic has meticulously engineered a statutory environment designed to facilitate, rather than penalize, the retention of wealth within the family unit. The philosophical foundation of this system operates on principles that are practically anathema to the logic of the United States or the United Kingdom. The state recognizes that the preservation of capital within the domestic economy, particularly capital tied to immovable property and family enterprises, provides long-term macroeconomic stability that outweighs the short-term fiscal injection of aggressive death duties. Consequently, the Italian succession tax is applied at remarkably low flat rates and features highly generous individual exemptions, known as the franchigia, which are calculated per beneficiary rather than applied to the estate as an aggregate whole.
For the most critical vector of wealth transfer—a spouse and direct descendants in the linear line, including parents, children, and grandchildren—the state imposes a remarkably benign four percent tax on the net value of the transferred assets. Crucially, this four percent rate does not apply from the first euro; it is applied strictly and exclusively to the amount that exceeds a threshold of one million euros per individual beneficiary. To contextualize this advantage for hnwi succession planning italy, if an individual leaves an estate to a spouse and three children, the first four million euros of that estate are transferred with absolute zero tax liability. Even beyond the immediate nuclear family, the rates remain exceptionally advantageous compared to global standards. For siblings of the deceased, the rate increases slightly to six percent, with a reduced franchise of one hundred thousand euros per beneficiary. For other relatives up to the fourth degree of kinship, such as first cousins, the six percent rate applies without any exemption threshold, while all other non-related beneficiaries face a maximum rate of eight percent on the overall net value. Furthermore, the state provides a special exemption of one and a half million euros for beneficiaries with severe disabilities pursuant to Law 104 of 1992, recognizing social obligations without resorting to punitive aggregate taxation.
When one juxtaposes the Italian baseline rate of four percent against the American or British baseline of forty percent, the arbitrage opportunity becomes blindingly apparent. However, the true mastery of Italian tax structuring does not rely merely on the statutory rates. It requires a profound understanding of how the Italian Revenue Agency determines the taxable base to which these rates are applied. In the Anglophone system, the forty percent rate is applied to the fair market value of the assets, requiring rigorous, independent, and often contested commercial appraisals upon the date of death. The Italian system, when dealing with immovable property, entirely discards commercial market value in favor of an archaic, highly suppressed bureaucratic metric known as the cadastral value.
The Cadastral Anomaly: The Core of the Real Estate Arbitrage
At the exact center of the Italian arbitrage strategy lies the concept of the cadastral value, a statutorily mandated metric that fundamentally divorces the taxable base of an immovable property from its actual, real-world commercial price. Unlike financial securities or liquid cash, which are taxed at their nominal face value, Italian real estate is taxed according to a notional construct derived from the rendita catastale, or cadastral income. This income is assigned to the property based on outdated assessments of its geographic microzone, its designated cadastral category, and its internal class. Because the Italian cadastral registry has not undergone a comprehensive, nationwide revaluation to align with current market realities in decades, these notional values are severely disconnected from actual commercial prices. It is a well-documented empirical reality that the cadastral value of prime Italian real estate is systematically thirty to forty percent lower than its commercial market value across standard assets. However, in the case of historically significant trophy assets—such as meticulously restored Renaissance palazzi in Florence, expansive waterfront estates on Lake Como, or sprawling aristocratic domains in Tuscany—the discrepancy can be vastly more profound, often resulting in a taxable base that is a mere fraction of the asset's trading price.
The mathematical formulation of this disparity is strictly codified in law and operates as a permanent structural wealth multiplier for the investor. To determine the exact taxable base for inherited real estate with full ownership, the base rendita catastale is subjected to a fixed statutory revaluation of five percent, and the resulting figure is then multiplied by a specific coefficient determined entirely by the property's use and cadastral classification. For a property designated as a primary residence, the multiplier is one hundred and ten. For secondary residential properties falling into the standard cadastral categories of group A, which excludes luxury offices and certain anomalous historical designations, the multiplier is one hundred and twenty.
Consider the practical, mathematical application of this formula to the concept of italy inheritance tax real estate using a prime, non-fungible asset. An investor acquires an iconic villa on the Amalfi Coast that trades on the open international market for an aggregate price of ten million euros. Due to the archaic nature of the cadastral registry, the property's historical designation, and the application of the statutory formula, the official cadastral value utilized by the Revenue Agency for taxation purposes might barely reach one and a half million euros. When the moment of succession arrives, the calculation is based entirely on this suppressed figure. If the property is inherited by a single child, the first one million euros of that cadastral value is completely neutralized by the franchigia. The remaining taxable base is a mere five hundred thousand euros. Applying the four percent succession tax rate for direct descendants yields a total inheritance tax liability of exactly twenty thousand euros.
The effective inheritance tax rate on a ten million euro commercial asset is thus a staggering two-tenths of one percent. It is analytically necessary to note that the transfer of real estate also triggers the mandatory application of the mortgage tax at a rate of two percent and the cadastral tax at a rate of one percent. However, the critical mechanism remains intact: these ancillary taxes are equally calculated on the suppressed cadastral value of one and a half million euros, rather than the ten million euro market price. The combined three percent levy adds only forty-five thousand euros to the total cost of transfer. In a comparable Anglophone jurisdiction, an equivalent ten million dollar asset transferred at death could easily trigger a tax liability numbering in the millions, frequently necessitating the forced liquidation of the property or the assumption of massive, high-interest debt by the heirs simply to satisfy the sovereign claim. In Italy, the asset is passed intact across the generational divide for the equivalent cost of a luxury automobile. The real estate ceases to be a fiscal liability and becomes the most efficient store of value available in the global marketplace.
Legislative Fortification: Decree 139/2024 and the Abolition of Coacervo Successorio
While the baseline combination of the four percent rate and the cadastral anomaly has long made Italy an attractive jurisdiction, the strategic environment was exponentially magnified by a wave of recent legislative evolutions. The enactment of Legislative Decree 139 of September 2024, which came into full force in January 2025 as a critical component of the government's broader rationalization of indirect taxes, introduced profound structural enhancements to the succession planning landscape. The most revolutionary and heavily lobbied of these changes was the explicit, definitive abolition of the archaic institution known as the coacervo successorio.
Under the obsolete pre-2025 regime governed by paragraph 4 of Article 8 of Legislative Decree 346/1990, the net value of an estate for the purposes of calculating the tax base had to be artificially inflated. The law forced the executors to add the value of all lifetime donations previously received by the beneficiary from the deceased to the value of the inherited assets, updating those past donations to their value at the time the succession opened. This cumulation effectively eroded the one million euro franchise prior to death, penalizing families who engaged in active lifetime wealth transfers. The complete eradication of the coacervo successorio principle under Decree 139/2024 fundamentally altered the mathematics of transferring property to children italy. The new system effectively created a dual, completely separate and independent exemption framework for inter vivos gifts and mortis causa transfers.
Under the current modernized structure, the one million euro exemption for lifetime gifts operates in total isolation from the one million euro exemption for inheritance transfers. This means that a patriarch can strategically transfer one million euros of liquidity, equity, or real estate equity to a child during their lifetime entirely free of gift tax. Upon the patriarch's demise, that exact same child is legally entitled to a fresh, wholly uncompromised one million euro franchise to be applied against the inherited estate. By merely separating the timing of the asset transfers, a family can seamlessly move two million euros of wealth to each direct descendant with an absolute zero tax liability. For a global family with three children, this equates to six million euros of entirely tax-free wealth transfer, completely shielded from sovereign extraction before the highly favorable four percent rate even begins to apply to the surplus capital.
This environment of unparalleled fiscal benevolence was further codified, streamlined, and permanently embedded into the legal architecture by the introduction of Legislative Decree 123 of August 2025. Supposedly anticipated to take full effect in January 2026, this monumental piece of legislative rationalization established the new Consolidated Act on Indirect Taxes, harmonizing the myriad, previously fragmented laws governing registration tax, mortgage and cadastral taxes, stamp duties, and the entire inheritance and gift tax regime into a single, coherent textual authority comprising over two hundred distinct articles. However the entry into force of the decree and its harmonized framework was formally prorogued to January 1, 2027, pursuant to the provisions enacted by the Decree Law 200 of December 31, 2025, commonly referred to within the Italian legal system as the Milleproroghe decree. Consequently, any strategic asset structuring relying on the consolidated textual authority of Decree 123/2025 must account for this delayed implementation horizon rather than operating under the assumption of a 2026 effective date.
In any case, the consolidation definitively removed layers of bureaucratic ambiguity that previously required complex, contradictory jurisprudential interpretation by the courts, replacing it with a modernized, transparent framework that firmly cements the rights of the taxpayer and guarantees the predictable calculation of long-term liabilities. Crucially, the decree explicitly reaffirmed the principles governing the determination of the taxable base for real estate based on the situation existing at the time the succession opens, signaling the state's enduring commitment to maintaining its position as a jurisdiction of unparalleled fiscal stability for the retention of hard assets.
Fiduciary Abstraction: The Evolution of Trust Taxation in Italy
For the highly sophisticated investor requiring an additional layer of structural abstraction and asset protection beyond direct ownership, the Italian jurisdiction has recently provided definitive, ironclad clarity on the use of trusts as an intergenerational holding mechanism. For many years, the taxation of trusts in Italy was paralyzed by an interpretative war of attrition between the Revenue Agency, which aggressively pushed for upfront taxation upon the initial transfer of assets into the trust structure regardless of ultimate distribution, and the Supreme Court of Cassation, which repeatedly ruled that taxation could legally only occur upon the actual distribution of wealth to the final beneficiaries, as only then was an actual enrichment realized.
This paralyzing legal friction was definitively resolved through the issuance of the Revenue Agency's Circular 34/E in October 2022, and subsequently permanently codified into binding national law by the sweeping provisions of Legislative Decree 139/2024. The Italian state has capitulated entirely to the logic of the courts, formally establishing that the execution of a trust deed and the subsequent transfer of real estate or financial assets into the trust by the settlor does not, in itself, trigger inheritance or gift tax. The taxable event is now legally deferred until the precise moment of final distribution of the assets to the ultimate beneficiaries, perfectly aligning the fiscal burden with the actual, realized enrichment of the individual rather than the abstract creation of the fiduciary vehicle.
Crucially, the new legislation dictates that when the taxation finally occurs upon distribution, the calculation of the tax, including the applicable rate and the availability of the one million euro franchises, is determined based on the familial relationship between the original settlor and the beneficiary at the time of the distribution. This ensures that assets held in trust for descendants retain the ultimate protection of the four percent rate. However, the true genius of the reform lies in the introduction of an innovative opt-in mechanism for advance taxation. Decree 139/2024 allows the settlor of the trust to voluntarily choose to pay the inheritance and gift tax upfront at the time of the trust's creation, settling the liability permanently based on the current value of the assets. Once this upfront tax is paid, no further inheritance or gift taxes can be levied upon the future distribution to the beneficiaries, regardless of how much the underlying assets may appreciate in commercial value over the intervening decades.
When a global investor utilizes an Italian trust to hold prime Italian real estate, this opt-in mechanism provides the ultimate, impenetrable fiscal shield. The settlor transfers the trophy asset into the trust, voluntarily opts into the upfront taxation, pays the negligible four percent tax calculated on the currently suppressed cadastral value minus the franchise, and completely insulates the asset from any future legislative volatility, market appreciation, or changes to the cadastral registry itself. The property can then be managed, enjoyed, and eventually passed to the heirs entirely outside the bounds of traditional probate, offering both unparalleled privacy and absolute, guaranteed fiscal efficiency that simply does not exist in any other major Western economy.
The Synergistic Shield: The Flat Tax Regime and Corporate Exemptions
The strategic utility of deploying capital into Italian real estate is amplified to its maximum potential when integrated with the nation's highly aggressive tax regime designed specifically to attract foreign human capital and ultra-high-net-worth individuals. The Italian lump-sum tax regime, originally introduced to lure mobile capital away from traditional low-tax jurisdictions like Switzerland, the United Arab Emirates, and Monaco, allows new tax residents to entirely bypass standard progressive income taxation on their foreign-sourced income in exchange for a single, flat annual payment. Originally set at one hundred thousand euros, the substitute tax was increased to two hundred thousand euros per year for individuals transferring their tax residence after August 2024 via Decree Law 113/2024, commonly known as the Omnibus Decree. Current legislative drafts for the 2026 Budget Law indicate a further prospective increase to three hundred thousand euros for new applicants, underscoring the high demand for the program.
Despite this escalation in the cost of entry, the regime remains profoundly advantageous due to its unparalleled peripheral benefits. The flat tax is valid for a maximum duration of fifteen years, and it can be extended to immediate family members for a supplementary fee of twenty-five thousand euros per person. Beyond shielding global dividends, foreign capital gains, and international real estate income from the reach of the Italian treasury, the flat tax regime confers an absolute, blanket exemption from the onerous wealth taxes typically levied on foreign financial investments and real estate held abroad, known respectively in the Italian code as IVAFE and IVIE. It also exempts the individual from the invasive foreign asset reporting obligations under the RW Schedule.
Most critically for the overarching theme of succession, individuals who opt into the flat tax regime are completely, unequivocally exempt from Italian inheritance and gift tax on all assets situated outside of the Italian territory. The strategic convergence of these independent legal frameworks is breathtaking in its elegance and efficiency. A global ultra-high-net-worth individual relocates their tax residency to Italy, activating the flat tax regime to entirely neutralize their global income streams and permanently protect their international portfolio from both wealth extraction and succession levies. For the duration of the fifteen-year regime, the only assets in their global portfolio exposed to the Italian inheritance tax regime are the physical properties and investments situated strictly within the Italian borders. Yet, as has been exhaustively demonstrated, the exposure of these domestic assets is not a liability, but an opportunity. The domestic real estate is structurally shielded by the cadastral value calculation, the minimal four percent rate, the dual exemptions resulting from the abolition of the coacervo successorio, and the option for perpetual fiduciary shielding via the new trust regulations. The individual achieves total global tax optimization while residing in a G7 economy, utilizing Italian prime real estate not as a fiscal trap, but as a heavily subsidized consumption asset that functions simultaneously as an impenetrable store of dynastic value.
Furthermore, the legal architecture provides seamless, frictionless avenues for the structuring of broader family wealth beyond simple real estate holdings. The Consolidated Act on Successions and Donations, as recently updated and reinforced, maintains sweeping, absolute exemptions for the transfer of family businesses and corporate participations. Under the highly specific provisions of Article 3, paragraph 4-ter of Legislative Decree 346/1990, the transfer of a business branch, corporate shares, or controlling corporate participations to a spouse or direct descendants is entirely exempt from inheritance and gift tax, without any monetary limit. The sole condition for this total exemption is that the heirs must maintain control of the entity or continue the business activity for a statutory minimum of five years from the exact date of transfer.
The recent Legislative Decree 139/2024 even extended the application of this exemption to cases involving an increase in existing controlling shareholdings and transfers of companies that are resident in the broader European Union or the European Economic Area. This provision allows patriarchs and matriarchs to structure highly complex holding companies, potentially incorporating their real estate assets, private equity stakes, and operating businesses into broader corporate entities, and pass the entirety of the corporate structure down the generational line without suffering a single euro of capital erosion. The recent decrees provided critical interpretative clarity, confirming that such tax-exempt transfers can be flawlessly executed through formal family pacts governed by the Civil Code or through the sophisticated use of trust structures, further harmonizing the corporate exemption with the modern instruments of international wealth planning.
Conclusion: The Trophy Asset as an Impenetrable Vehicle
The stark, unassailable reality of the current global macroeconomic environment is that wealth is no longer safe in the jurisdictions that birthed the modern financial system. The United Kingdom's ideological shift toward global wealth extraction, evidenced by the ruthless dismantling of the non-domiciled regime and the taxation of excluded property trusts, has terminated London's viability as a generational safe haven. The United States' persistent reliance on volatile, high-rate estate taxation, trapped in a cycle of temporary reprieves and political brinkmanship, fundamentally alters the calculus of risk for the international elite, demanding constant legal maneuvering to avoid a forty percent capital decimation. In this environment, asset protection is no longer a matter of simply generating outsized investment returns to outpace the drag of taxation; it requires the physical, legal, and structural relocation of capital into jurisdictions that inherently respect and subsidize the continuity of family wealth.
Italy's transformation into this premier safe harbor is not an accident of bureaucratic inefficiency, but the result of a deliberate, highly sophisticated legislative evolution culminating in the sweeping decrees of 2024 and 2025. The definitive abolition of the coacervo successorio, the final, pragmatic rationalization of trust taxation, the comprehensive consolidation of the indirect tax codes, and the steadfast, politically entrenched defense of the cadastral valuation system have forged a fiscal environment entirely without equal in the Western hemisphere. The state actively facilitates the retention of physical assets within the family lineage because the bureaucratic apparatus acknowledges the immense capital required to maintain and preserve the nation's architectural heritage. By applying the minimal four percent tax rate to an artificially deflated cadastral base, the state engages in a silent, mutually beneficial covenant with global capital: bring your wealth to our shores, preserve our historic inventory, stimulate the luxury economy, and we will protect your lineage from the confiscatory mechanisms that are currently ravaging the Anglophone world.
In this precise paradigm, the acquisition of Italian prime real estate ceases to be viewed through the narrow, superficial lens of lifestyle acquisition or aesthetic indulgence. Instead, it must be recognized for exactly what it is: the most sophisticated, legally unassailable tax arbitrage available in the modern global economy. The Italian trophy asset, whether it be a sprawling estate in Tuscany or a historic palazzo in Rome, is an impenetrable fortress, a generational shield explicitly designed to absorb massive influxes of global capital, protect it from the predatory instincts of the sovereign state, and transmit it intact across the boundaries of mortality. For the family office and the ultra-high-net-worth individual, the deployment of capital into the Italian real estate market, structured through the precise application of the republic's fiduciary and fiscal laws, represents the ultimate mastery of succession planning in the twenty-first century.
Sources:
krestonreeves.com
Charges to offshore trusts from 6 April 2025 - Kreston Reeves
nhllp.com
End of UK Non dom Regime - Article Gerrards Cross - Nunn Hayward
gov.uk
Reforming the taxation of non-UK domiciled individuals - GOV.UK
saffery.com
Inheritance tax reforms for UK non-doms - Saffery
haysmac.com
Major UK tax changes for offshore trusts from 2025: What you need to know - HaysMac
merceradvisors.com
Estate Tax Exemption 2026 Changes Still Need 2025 Planning - Mercer Advisors
fidelity.com
What is the estate tax exemption? - Fidelity Investments
irs.gov
Estate tax | Internal Revenue Service
citizensbank.com
Estate Tax and Gift Tax Exemption to Sunset in 2026 | Citizens Private Bank
tfelawfirm.com
The 2026 Sunset of Increased Estate and Gift Tax Exemption | Thomas, Fisher & Edwards
bankerslife.com
What to Know About Estate Taxes in 2026 - Bankers Life Blog
avemarialaw.edu
Estate Planning and the Sunset of the TCJA: What to Do Before 2026
irs.gov
One, Big, Beautiful Bill provisions | Internal Revenue Service
dglaw.com
After the One Big Beautiful Bill: Estate Tax Updates - Davis+Gilbert LLP
irs.gov
What's new — Estate and gift tax | Internal Revenue Service
morganlewis.com
IRS Announces Increased Gift and Estate Tax Exemption Amounts for 2026 - Morgan Lewis
n26.com
Inheritance Tax in Italy: How does it work? - N26
wise.com
Inheritance tax in Italy (UK Guide) - Wise
mazzeschi.it
A Quick Guide to the Italian Inheritance Tax - Mazzeschi
studiogaeta.com
Italian inheritance and gift tax: double exemption benefit for foreign ...
biblus.acca.it
Imposta di successione e donazione 2025: cos'è e come si paga - BibLus ACCA
gabrielesepio.com
I trust del Dopo di noi restano tassati in uscita per gli eredi del beneficiario 2.Possibile la scelta di pagare all'apertura - Gabriele Sepio
theitalianlawyer.com
Italian Inheritance Tax: calculation updates from 2025
basecamp-ecoresorts.com
Tax implications of a Second Home in Italy | Basecamp Eco-resorts
lexunion.com
Italian inheritance and gift tax reform | Lexunion - International Legal & Notarial Strategies
it.andersen.com
Reform about rationalization of indirect tax other than VAT ...
galvanifiduciaria.it
Modifiche al Testo Unico sulle successioni e donazioni: novità in materia di trust
notaiodilauro.it
Le modifiche del D.Lgs. 139/2024: abrogazione definitiva del coacervo
federnotizie.it
Le modifiche del D.Lgs. 139/2024: abrogazione definitiva del coacervo nelle successioni
wp.belluzzo.net
GIFT & SUCCESSION TAX REFORM IN ITALY - Belluzzo International Partners
fiscal-focus.it
Successioni e donazioni: addio definitivo al coacervo successorio - Fiscal Focus
arlettipartners.com
Inheritance Tax and Bank Current Accounts: the Actual Balance as at the Date of Death Prevails - Arletti Partners
arlettipartners.com
Italian inheritance tax law and international succession - Arletti Partners
5rs.it
Tax update
def.finanze.it
Testo unico del 01/08/2025 n. 123 - Documentazione Economica e Finanziaria
addiopignoramenti.it
Cartella Esattoriale Per Imposte Ipotecarie: Come Difendersi - Tutte
taxathand.com
Decree on consolidated text of VAT Code is in final stage of approval process - tax@hand
avvocaturastato.it
Appunti sul D.lgs. n. 139/2024 Modifiche in materia di trust - Avvocatura dello Stato
euitalianinternationaltax.com
Taxation of Trusts | European Union and Italian International Tax Law Blog
maisto.it
Circular Letter 20 October 2022, No. 34/E ITALIAN REVENUE AGENCY ISSUES GUIDELINES ON THE TAXA- TION OF TRUSTS
geometri.vi.it
NUOVE DISPOSIZIONI SUCCESSIONI E DONAZIONI 2025
dirittobancario.it
I trust e la nuova Imposta sulle successioni e donazioni - DB - Diritto Bancario
boccadutri.com
Flat Tax for new residents in Italy: 2025 guide
italiancitizenshipassistance.com
Italian Flat Tax Regimes: What Are They and How Do They Work?
taxsummaries.pwc.com
Italy - Individual - Taxes on personal income
insightplus.bakermckenzie.com
Italy: Government intends to increase again the flat tax on foreign-sourced income for new residents - Baker McKenzie
arlettipartners.com
New Increase of the Flat Tax in the 2026 Draft Budget Law - Arletti Partners
arlettipartners.com
The Preferential Tax Regime for Businesses Inheritance in Italy - Arletti Partners
internationaltaxreview.com
Trusts and business transfers: are Italian tax exemptions applicable to advance taxation?
chambers.com
ITALY: An introduction Law | Chambers and Partners
