A new chapter in Italy: Guiding a European billionaire’s move
Our International Private Client Partner Nicola Saccardo was instructed to help an ultra-high-net-worth client based in Europe relocate to Italy, and has since been invited to provide further wide-ranging advice.
The client holds a wide variety of assets – including a substantial shareholding in the holding company of the family business, several actively managed financial portfolios and luxury assets including yachts and residential properties privately used by him and his family – through several holding structures in multiple jurisdictions.
The client moved to Italy under a lump sum tax regime, and at the time of his relocation, we obtained a very favourable ruling from the Revenue Agency (Agenzia delle Entrate), which ensured that these entities would not be exposed to corporate income tax in the country because they originated from foreign sources.
Since then, we have strengthened our relationship with the client and more recently, we have assisted them on complex tax, succession, family and real estate related issues.
Upon death, the client intends to dispose of their assets in a way that may not be consistent with Italian forced heirship rules. In contrast to English law, whereby individuals can leave their assets as they wish, Italy has forced heirship rules which entitle certain next of kin to claim specific portions of the deceased’s estate. The application of Italian succession law, however, can be avoided with appropriate planning, and we have advised our client on how to ensure his succession plan is not challenged by family members in the future.
In addition, significant changes to the client’s original holding structures have been considered for succession planning purposes. Considering these might have an impact on the tax ruling previously obtained, we secured a new ruling from the Revenue Agency last year, confirming the tax treatment of the structures would remain unchanged.
We have also advised the client on the purchase of a residential property in Italy.
Nicola has led the work from our London office with the support of Senior Associate, Gabriele Colombaioni, as well as Partner, Maria Cristiana Felisi and Counsel, Francesco Giovanni Angelini in our Milan office.
The work highlights the breadth of our Italian expertise, which covered both tax and legal matters. The client appreciates the broad scope of our services, as well as the possibility of involving international colleagues – where required – and our own international expertise, including our familiarity with complex offshore trust and foundation holding structures.”
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