Territorial Scope of Italian Inheritance and Gift Tax

General rule

• Deceased/donor resident in Italy: The tax applies to all transferred assets and rights, wherever located (worldwide taxation).

• Deceased/donor not resident in Italy: The tax applies only to assets and rights situated in Italy.

Assets deemed “in any event” to be situated in Italy (for territorial purposes), notably:

• Assets and rights registered in Italian public registers, including related real rights;

• Shareholdings (shares/quotas) in companies or entities with their registered office, place of management, or principal activity in Italy;

• Bonds and securities issued by the Italian State or by Italian entities;

• Receivables and negotiable instruments where the debtor/drawee/issuer is resident in Italy;

• Receivables secured on assets located in Italy, up to the value of the secured assets, regardless of the debtor’s residence.