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Archive » March 2023 » Taxation of trusts in Italy: what’s new in the light of the recent Revenue Agency circular

Taxation of trusts in Italy: what’s new in the light of the recent Revenue Agency circular

Enzo Mignarri
March 2023 - n. 3
Keywords: Trust, imposte dirette, imposte indirette
Jel codes: K30, K34

In recent years, the taxation of trusts in Italy has seen new regulation on direct taxation, and a series of rulings of the jurisprudence of legitimacy about indirect taxation, followed by a recent circular of the Revenue Agency. With regard to inheritances and donations, the circular, overcoming previous positions, took note of the recent jurisprudential guidelines according to which the prerequisite for the application of the tax does not occur at the time of the establishment of the trust or the deed with which it is endowed with an asset, but only when an effective enrichment of the beneficiaries is achieved, with the definitive passage to them of the assets of the trust.

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