Nuovi obblighi RW per Trustees e/o Beneficiari in relazione a soggetti italiani

Italy and Trust. Since 1992, when the Hague Convention was ratified, Italy has been very active on trusts.  Several official interpretation and guidelines affecting trusts have been issued by the Italian Inland Revenue (“Agenzia delle Entrate”) since 2007, on both direct (i.e. circular 48/E/2007) and indirect taxation (i.e. circular 3/E/2008).
It is important to note that under Italian tax law, the trust is subject to the Italian corporation tax (IRES) and to a gift tax applicable on the funds transferred to the trust. Recently, after the rewording of art.41 of Law Decree n° 167/90 (“167/90”), Italian tax residents are
required to disclose the value of foreign assets directly and/or indirectly owned.

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