Abstract
Abstract New rules in Italy are now reshaping years of discussion about the use of non-tax resident trusts. Although the new law places certain interpretative issues, in the following article, the author analyses the main concepts and the impact of Article 13 of Law Decree 124/2019 in connection with guidelines previously issued by the Italian Tax Office and circular newsletter 61/E/2010 in particular. For non-Italian resident trusts, the distinction between capital and income, within the Italian meaning and according to the new (tax) assumption also related to black-listed income, is of paramount importance as the new rules set the tax treatment for trust attributions to Italian tax resident trust beneficiaries.
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