We are Italian tax lawyers, working alongside a team of chartered accountants. That combination is unusual, and it is the reason this page exists, because in Italy the two professions do different work and are normally engaged separately.
The lawyer advises on what the law requires, structures the position before it is taken, obtains binding confirmation from the authorities where that is worth having, and defends the position if it is challenged. The accountant computes, files, and keeps the position compliant year after year.
Split across two firms, the space between them is where most problems begin: advice that nobody implemented, filings that nobody checked against the advice, and a challenge that arrives at a firm which never saw the reasoning.
Before any regime, any rate or any filing, one question decides the shape of the answer: whether you are an Italian tax resident for the year in question.
A resident is taxed here on income wherever in the world it arises, must report assets held abroad, and pays annual charges on foreign property and foreign financial holdings. A non-resident is taxed only on income treated as arising in Italy, and reports nothing.
And residence is not a matter of choice or of paperwork. It is established by four alternative criteria — habitual abode, domicile, physical presence counting part-days, and registration with a municipality — any one of which, met for the greater part of the year, is enough. People arrive believing they have decided their residence position, and discover that the calendar decided it for them.
The corollary matters commercially: almost every decision worth taking has a window, and the window usually closes on arrival. That is why the first conversation is better held early than well-informed.
We work from primary sources — the legislation, the implementing decrees, the circulars, the case law — rather than from summaries of them. A surprising amount of what circulates in English about Italian tax is out of date by a year or more, and some of it was never right; the difference only becomes visible when a position is tested.
We say when something is unsettled. Where two readings of a provision are tenable we give both and explain which we would run and why, because the alternative is confidence that costs the client money later.
And we stay on the file. The person who structured the position prepares the filings that implement it and answers for it if it is challenged. Nothing is handed to a second firm halfway through, which is the point of having both professions in one place.
The decisions that change outcomes here are nearly all decisions about sequence: when residence begins, what is done before it begins and what after, which election is made in which year, how an asset is held at the moment it becomes relevant. Once residence has attached, the set of available answers narrows sharply and some of them close entirely.
The corollary is that a short conversation before a move is worth more than a long one afterwards. Most people arrive asking about a regime they have read about; the more useful first question is what you have, where you will be, and when — because that determines which regimes are available to you at all.
These are written from primary sources and cite them, and they are kept current rather than left to age — which, in a field where the rates changed twice in eighteen months, is most of what makes a guide useful.
Two professions in one firm: the advice, the election, the filings that implement it, the ruling where one is worth obtaining, and the defence if the position is challenged.
Primary sources rather than summaries, and an explicit answer where the law is unsettled rather than a confident one.
A practice built around clients whose lives are in more than one country, which is a different problem from Italian tax practised for Italians.
What you have, where you will be, and when. That is what determines which regimes are even available — and it is a shorter conversation than reading about all of them.
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