National and International Tax Advisory

A holding company enables significant tax optimisation through instruments such as participation exemption (PEX), tax consolidation and preferential taxation of dividends. It also provides asset protection, centralised management of shareholdings and enhanced financial control. It is particularly suitable in the presence of multiple operating companies, substantial assets or international group structures.

A holding company allows the concentration of shareholdings within a single entity, thereby simplifying the transfer of ownership to heirs. This reduces family conflicts, ensures business continuity and preserves the unity of the family wealth. It is a key tool for structuring an orderly and tax-efficient generational transition.

A holding company allows the centralisation of profits, dividends and financial flows within the group. Thanks to the PEX regime, capital gains and dividends may benefit from significantly reduced taxation. In addition, instruments such as tax consolidation allow the offsetting of profits and losses, improving the overall tax sustainability of the group.

Yes. The Italian Flat Tax for new residents allows high-net-worth individuals to tax foreign-source income with a fixed annual lump-sum tax, regardless of the amount of income. Following the abolition of the UK “res non dom” regime, Italy is now one of the leading tax alternatives in Europe for HNWI considering a change of tax residence.

The regime allows pensioners with foreign-source income who transfer their tax residence to specific municipalities in Southern Italy to apply a 7% substitute tax. The incentive applies for up to 10 years and is reserved for individuals who have not been Italian tax residents in the previous five years. Income produced in Italy remains subject to ordinary taxation.

The regime allows individuals who transfer their tax residence to Italy after at least nine years of non-residence to tax their foreign-source income with an annual lump-sum tax of €200,000 (€300,000 from 2026). The option may be extended to family members upon payment of an additional amount. The regime ensures tax certainty, simplification and advanced wealth planning.

Tax neutrality allows the reorganisation of shareholdings and contributions without immediate taxation of capital gains. This makes it possible to set up a holding company without initial tax impacts, while centralising corporate control. If properly structured, the holding company may also benefit from the PEX regime on dividends and share disposals, optimising group taxation.

The transfer results in the shift of taxation to the new State of residence. In the event of relocation abroad, exit tax may apply on latent capital gains. If the new structure lacks effective economic substance, the transaction may be challenged as tax residence abuse (esterovestizione), with significant tax and penalty consequences.

Yes. Registration with AIRE is mandatory for Italian citizens who transfer their residence abroad for more than 12 months. It is an administrative requirement distinct from tax residence, but highly relevant for tax audit purposes. Failure to register may result in penalties and tax assessments.

There is no single solution that is suitable for everyone. Planning must always be custom-made, based on the assets involved, family situation, objectives and relevant jurisdictions. Depending on the case, instruments such as trusts, holding companies, fiduciary arrangements and mandates may be used, also in combination. Effectiveness depends on their proper integration within a coherent overall structure.

The neo-domiciled regime allows all foreign-source income to be subject to the lump-sum tax, including investment income, financial capital gains, foreign real estate income, dividends, interest and income from participations. Income produced in Italy remains subject to ordinary Italian taxation. The regime also provides an exemption from foreign asset monitoring obligations.