Abstract
This article analyses the new special tax regime for high-net-worth individuals, pursuant to which non-resident individuals transferring their tax residence to Italy can opt to pay a lump sum substitute tax of EUR 100,000 per year, in lieu of ordinary taxation, on all of their non-Italian sourced income. Such preferential regime is a withdrawal from the traditional worldwide taxation and unlimited tax liability. Trusts and other interposed structures will benefit from the same rules applicable to qualifying high-net-worth individuals.
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