‘Dolce Vita’ in Italy for ex-UK non dom

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A high net worth individual (HNWI) who was formerly registered as non-domiciled in the UK has become the first person to be granted resident non-dom status in Italy, under the country’s new regime introduced at the start of the year

The man, who was represented by international law firm Withers, is said to have decided to move to Italy to take advantage of the new status and to establish a new hub for his family.

Giulia Cipollini, head of Withers Italian tax team, said: ‘Our client has been non-tax resident in Italy for the past nine years and owns assets and investments around the world and has been the director of several non-Italian companies.

‘He is a great illustration of how the Italian res non-dom scheme can be extremely attractive for internationally mobile individuals and we're delighted to have been able to secure the first approved non-dom application.'

The Italian non-dom regime has been in effect since January 2017. On launching the regime, the Italian Revenue Agency said: ‘This favourable tax regime is available for “newly resident” individuals in Italy, who (regardless of their nationality or domicile) have been non-tax resident in Italy for at least nine years out of the 10 years preceding their transfer to Italy. The incentive regime may be also extended to the family members of these individuals.’

The new regime is available to anyone (regardless of their nationality or domicile) who has been non-tax resident in Italy at any time during the nine years preceding a relocation to Italy, including Italian returnees. The rules identify individuals as tax resident if they are a registered Italian citizen or reside in Italy for more than half the year (183 days).

The rules require that Italian-source income and gains are taxable in the usual way; but allow foreign income and gains to be sheltered from Italian tax, provided the taxpayer pays an annual charge of €100,000.

The option is valid for a period of 15 years, and election for the regime may be extended to family members through the payment on their foreign income and gains of a substitute tax amounting to €25,000 per member.

At the time of its introduction, there was speculation that the Italian offer could prove attractive to HNWIs looking at relocating from the UK as their base, following changes to the non dom regime here.

In its announcement of their client’s recent move, Withers said the new non-dom regime ‘combines with several other Italian tax incentives (including one of the lowest levels of both inheritance and gift taxes in Europe, exemptions on capital gains on certain categories of real estate and art works and a new tax regime applicable to carried interest derived by fund managers) to make the country a very attractive destination for foreign investors and high net worth individuals.’

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