This article addresses the transposition of the legal relationship known as a “trust” into Italy, a civil law system. It analyses how trusts participate in tax proceedings and the extent to which transposition, under the current legal framework, remains incomplete. The fact that it is the trustee rather than the trust that participates in certain proceedings potentially conflicts with the ability-to-pay principle. Finally, the author proposes that trusts should be treated as companies for tax proceeding purposes.