Transfer of bare ownership of partnership interests also eligible for tax exemption

The transfer of shares or interests by way of inheritance or gift is exempt from the relevant inheritance and gift taxes where, in the case of companies, the transfer results in the acquisition or strengthening of control over the company and such control is maintained for at least five years.

In the case of partnerships, the exemption may also apply where only the bare ownership of the partnership interest is transferred, provided that all rights relating to the management of the partnership are vested in the bare owner.

This position has been clarified by the Italian Ministry of Economy and Finance in a recent official communication.