Italian tax ramifications for Liechtenstein foundations and trusts in the light of the new guidance of the Italian tax agency. 25 May 2023

Topic: Italian tax ramifications for Liechtenstein foundations and trusts in the light of the new guidance of the Italian tax agency

The following aspects are covered:

• After a long wait on October 20, 2022, the Italian Revenue Agency published Circular letter No. 34, including the new guidelines on the tax legislation applicable to trusts and foundations.
• The clarifications are many – as are the area of uncertainties still pending – and taken together determine a substantial “revolution” of the way Italian tax rules should apply to trusts and foundations.
• One of the effects of the Circular is certainly to increase the number of duties and complexities that foreign trustees and professionals managing private foundations with Italian ramifications are required to cope with in order to avoid negative tax consequences for the trust/foundation itself and its beneficiaries.
• The new regulatory scenario, however, still enables the possibility of Liechtenstein foundations continuing to be a useful tool for generational transition planning in certain cases.

Speakers:

• Paolo Ludovici, Equity Partner, Studio Legale GattiPavesiBianchiLudovici, Milano
• Andrea Gallizioli, Junior Partner, Responsible Luxembourg office GattiPavesiBianchiLudovici www.legalegpblex.it