Italian resident individuals with interests in Liechtenstein entities: notes on Italian income taxes—Part 2

Abstract

It is not uncommon for Italian resident taxpayers to resort to Liechtenstein entities for taking advantage of the benefits that they can offer, like asset protection, confidentiality and favorable taxation. After having dealt, inter alia, with Liechtenstein foundations and establishments in Part 1, Part 2 focuses on the holding of participations in Liechtenstein limited companies by Italian resident individuals. In this regard, the tax treatment of dividends, capital gains and “the Italian Controlled Foreign Companies regime” are addressed. Finally, a few remarks are made on some income tax planning opportunities and criticalities in light of the Italian tax legislative framework described in Part 1 and Part 2.