Black List Countries

Presumption of Tax Residence Article 2, paragraph 2-bis of the Italian Income Tax Code (TUIR – Presidential Decree No. 917/1986) contains a specific anti-tax avoidance provision concerning the tax residency of Italian citizens. Reversing the Burden of Proof: This provision establishes a rebuttable presumption that an Italian citizen who transfers their residence to a country […]

IVIE Tax Base Post Brexit

Brexit has had a potentially expensive impact for Italian tax residents owning real estate in the UK.  Italian tax residents are required to pay a wealth or ownership tax on foreign (ie. non Italian) real estate (unless the property is owned and occupied as a principal residence.  As a result of Brexit,  in the view […]

Foreign Asset Reporting, Section RW, IVIE & IVAFE – Wealth Tax on Foreign Property

Increase in IVIE and IVAFE Starting from FY 2024, the rate of  IVIE,  the tax on the value of foreign (non Italian) real estate located abroad, will increase from 0.76% to 1.06%.  This increase applies generally to all real estate situated outside Italy by a Italian tax resident.    IVAFE, the tax on the value […]