First-time implementation of tax rules for trusts in Italy

The Italian Finance Bill for 2007 has, for the first time, introduced tax provisions for trusts. The new rules primarily cover (1) the qualification of trusts as taxable persons, (2) the circumstance in which trusts are deemed to be resident in Italy for tax purposes and (3) the application of a tax transparency regime to certain trusts. The rules apply to income arising from 1 January 2007, regardless of when the trust was established.