The Italian RND Regime

This case study looks at the Italian “lump sum" taxation regime introduced in 2017.

Key learning points

In this case study we look at the Italian “lump sum" taxation regime introduced in 2017 and its ramifications for international HNW clients moving to Italy.
  • Background to the Italian lump sum regime
  • Foreign pensioners regime
  • Timing of departure from the UK and the Italian tax year
  • Immigration issues
  • Costs of the Italian lump sum regime and regional variations
  • Taxation of UK rental income under the lump sum regime
  • Taxation of non Italian portfolio gains under the lump sum regime
  • Use of life assurance bond
  • Capital gains on shareholdings
  • Taxation of non Italian earned income under the lump sum regime
  • Taxation on trust distributions
  • Impact on lump sum regime if grown up children relocate too

Nicola Saccardo

Nicola is a partner at Charles Russel Speechly and advises clients on Italian tax. Much of his work is centred around the relocation of HNW individuals to Italy and the Italian taxation of trusts, as well as estate tax planning.

Nicola is the Chair of the Tax Committee of the International Academy of Estate and Trust Law, a member of the International Estate Planning Committee of ACTEC and the Chair of the International Client Global SIG Steering Committee of STEP. He is the editor of the International Family Offices Journal.
Nicola is admitted to practise in Italy, both as a lawyer and as a chartered accountant.
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