Italian Revenue Agency Provides New Guidance on the Taxation of Trusts

In this article, the author examines Circular Letter No. 34/E of 20 October 2022 on certain aspects of the taxation of trusts, which provides guidance on two specific issues, i.e. the tax treatment of “attributions” in favour of subjects resident in Italy from trusts established in “privileged taxation jurisdictions” and the form of application of the inheritance and gift tax in respect of assets transferred to a trust fund.