In two tax rulings published on 28 May 2025 (Replies No. 144 and 145), the Italian Revenue Agency (“Agenzia delle Entrate”) revisited the ever-topical issue of the direct taxation of foreign trusts, addressing both the trust’s status as a taxable person and the levy on Italian-source income.
The European Commission has closed the file opened upon AIDC’s report on Controlled Foreign Companies (CFC), concluding the procedure in a manner favorable to taxpayers.
On 19 November 2024, the Italian Tax Authorities issued Circular Letter n. 23/E/2024 aiming to clarify the IME rules. Our Focus Update provided a brief examination of the IME rules and of the clarifications provided by the Italian Tax Authorities.
Our Guide for Foreign Investors is available on request and aims to provide a first reference of the relevant rules related to Italy from the perspective of a foreign investor.
Belluzzo International Partners is a multidisciplinary, international and independent professional boutique that provides consultancy in the areas of Wealth, Law, Tax, Finance.
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