In Italy, the legislation on the determination of tax residency for natural persons (individual taxpayers) changed in 2024. The most significant changes concern the new definition of “domicile”, which is one of the four alternative criteria used to determine personal tax residency for income tax purposes, and the enactment of the new physical presence rule.
2024
Trust termination by mutual consent triggers no tax, settlor regains title to trust assets, Italian Tax Agency rules
By Marco Rossi on
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…