ANSWER TO RULING NO. 251/2023: THE ITALIAN TAX AUTHORITIES INTERVENED AGAIN ON FOREIGN INTERPOSED TRUSTS. TAX TREATMENT, TAX COMPLIANCE AND MONITORING OBLIGATIONS FOR BENEFICIARIES TAX RESIDENT IN ITALY.
By answer to ruling no. 251 of March 16th, 2023, the Italian Tax Authorities intervened again on the interposition of two foreign trusts, clarifying the relevant tax treatment and the tax compliance and monitoring obligations for beneficiaries tax resident in Italy.
An individual, tax resident in Italy as from fiscal year 2014, established two trusts regulated by the Australian law:
(a) a “Family Trust” including among the beneficiaries the settlor (deceased on 2019), his wife and three sons. The trustee of this trust is a foreign company owned by some natural persons chosen among the beneficiaries;
(b) a “Testamentary Trust” including among the beneficiaries the settlor’s sons, grandsons and great-grandsons. The trustees of this trust are some natural persons chosen among the beneficiaries.
