In its Ruling n. 359 of July 4, 2022 (Risposta_351_18.05.2021-2) the Italian Tax Agency ruled that a trust which is disregarded for income tax purposes under the standards of Circular n. 61/E of December 27, 2010 is still respected as a complete and effective trust for Italian gift and estate tax purposes. As
Taxation of Trusts
Discretionary Beneficiary of Irrevocable Trust Required to Disclose Trust on Italian Tax Return
With its ruling n. 693 of October 8, 2021 (Prassi – AGENZIA DELLE ENTRATE – Risposta 08 ottobre 2021, n. 693), the Italian Tax Agency held that a discretionary beneficiary of a foreign irrevocable trust, treated as a fiscally opaque trust under Italy’s tax classification rules, is required to report his beneficial interest…
No Transfer Taxes Apply To Distribution of Trust Property to Settlor Upon Termination of the Trust, Italy’s Supreme Court Rules
By Marco Rossi on
With its ruling n. 8719 of March 30, 2021(Cass. n. 8719, 30-3-2021) the Italian Supreme Court ruled that no Italian gift tax applies when the trust assets are distributed back to the settlor, upon termination of the trust following the trust beneficiaries’ disclaimer of their beneficial interests under the trust.
The case involved…