Among various corner view, it is interesting to underline the tax & legal one, as it is going to set further pressure on the Italian New Tax Resident Regime (also called the “Italian Flat Tax”), where a new law, started on January 1st 2017, is giving the option for a € 100.000 flat tax on all income produced from foreign assets of the new tax resident in Italy.
Of course condition applies and we refer you to the 2 set of slides we have prepared @ Belluzzo.
It is further interesting that CR7 structure, as emerged by an article of Andreoli/Busani on Il Sole 24 Ore of 11 July gives further room to the effectiveness of this plan, as the whole of foreign assets appears to be inked through a Luxembourg company owned by an International trust. A full legitimate structure, which works very well for the new Italian regime, also according to circular newsletter 17/E/2017 from the Italian Tax Office.
Basically the new regime gives room to a structuring where the football champion is going to pay taxes in full on his income in Italy and is going to pay a flat tax of € 100.000 (eventually with extension of €25k per individual of his family option for entering the regime) for a maximum of 15 years. The new regime is also very effective on Inheritance planning, as the flat tax covers also all Italian indirect taxation (e.g. gift tax) on asset held abroad.
In the specific case, CR7 may find further convenience applying the new Italian law as it is possible to structure that some rights, related to exhibitions held abroad, could take the benefit of the treaties as the new regime gives a full coverage of the Italian convention to avoid double taxation.
It is not possible to comment further, but we decided to present this very brief comment as many newspapers commented about it.
