US Wealth Migration to Italy Surges: Flat Tax Regime rise, Trust Challenges and Forced Heirship Risks in 2026

Date: 22 Jan 2026

Karen Jones

Italy has attracted growing numbers of high-net-worth individuals and families relocating from abroad, including a significant and ongoing proportion from the United States.

Italy update

Factors cited, for the US move to Italy, include lifestyle preferences, historic family connections, business prospects and specific tax arrangements for new residents. Italy’s long tradition of family-owned businesses, such as Ferrero who own Nutella and confectionery; Prada and other luxury fashion houses, Ferrari, Barilla (pasta), and the Agnelli family’s extensive holdings in Fiat and beyond, means local advisers have substantial experience in private client issues, including succession planning, wealth transfer and intergenerational structures under the country’s civil-law system.

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More flat tax increases

Recent changes include an increase in the annual flat tax on foreign-source income under the new-resident regime to €300,000 from €200,000, for those establishing tax residency on or after 1 January 2026. This is something Switzerland advisors, push back on, saying it does not provide reassurance or certainty with so many, frequent increases in the annual, flat tax charge. Alongside the introduction of a 33% capital gains tax rate on cryptocurrency assets from the same date.

Despite the tax changes for good or bad and the American ‘gold rush’, further, persistent questions persist over the treatment of trusts, succession rules and philanthropic vehicles under Italy’s civil-law system, which includes strict forced heirship requirements – despite the EU providing a level of harmonisation across the different legal systems.

Italy as a Full-Spectrum Base for Internationally Mobile US Families

Davide Cotroneo, Tax Supervisor at BDO Italy and an Italian tax expert offers his thoughts. “It is important to be precise about terminology. ‘US persons’ is not a single category. US citizens are subject to citizenship-based taxation and remain within the US tax net regardless of where they live. Italy does not remove US tax constraints, and it is not positioned to do so. What Italy can offer, where the facts support it, is a domestic framework that is comparatively structured and predictable, allowing a relocation decision to be evaluated through a broader lens that includes governance, legal certainty and family considerations, rather than headline rates alone.”

“Italy’s appeal to HNWIs rests partly on the availability of favourable tax regimes that can be deployed selectively depending on profile and objectives. The new-resident regime under Article 24-bis of the Italian Income Tax Code “TUIR”, remains a central positioning tool for internationally mobile individuals, and it sits alongside an updated inbound worker framework and a favourable regime for carried interest that is directly relevant to fund principals.”

TUIR is the acronym for Testo Unico delle Imposte sui Redditi: the main body of Italian law governing personal and corporate income taxation.

“This matters acutely to US persons who are professionally active in asset management and are considering Italy as a base. The traditional structural deterrent has been permanent establishment risk for foreign investment vehicles when senior decision-makers relocate and perform investment activity in Italy.”

“Italy has responded to that deterrent directly by introducing an investment management exemption within its permanent establishment framework. In policy terms, this is a meaningful pivot. The exemption is designed to reduce the risk that a non-Italian investment structure becomes exposed to Italian taxing rights merely because investment professionals operate from Italy, provided a defined set of conditions is met around the nature and independence of the investment vehicle, the position of the asset manager, and the arm’s-length basis of remuneration.”

“The Italian Revenue Agency’s operational guidance reinforces that the exemption is intended to support the localisation of investment professionals without automatically recharacterising the wider investment structure as having an Italian taxable presence, and it also makes clear that the framework is conditional rather than automatic.”

Real estate investments using corporate equity

“Italy’s proposition is also unusually strong where personal relocation is paired with operating investment. Over the years we have seen internationally mobile families, including US and UK individuals, combine residence in Italy with the acquisition of an Italian agricultural business holding a mixed-use estate. This is because Italy’s framework treats agricultural companies and land-based activity through distinct corporate and property-tax concepts that are not a mere extension of ordinary commercial rules. Structurally, these investments are often executed through corporate equity rather than direct real estate acquisition, which can carry a different transfer-tax footprint.”

“Recent reforms have also provided greater clarity on the timing of Italian transfer taxation for assets settled into trust arrangements, leaning towards taxation at distribution to beneficiaries rather than immediate taxation on settlement which could still be opted by the taxpayer as an alternative regime, subject to the trust being recognised as a genuine arrangement rather than a mere conduit.”

Cotroneo makes his final point. “For US persons, this matters because US estate and gift tax concepts can place significant weight on completed transfers and long-term governance outcomes.”

The following views from advisers working with US clients illustrate how these broader trends and tax changes are playing out in practice.

US Citizens Moving to Italy: A Growing Trend Driven by Lifestyle and Tax Incentives

Paul Joseph Rausch, Partner, at JS Bongiovanni Company (JSBC), a US accounting, and business consulting firm based in Chicago but who also operate from Italy, offers his view: “Over the past year, our firm, along with many of the cross border advisory firms we work closely with between Italy and the United States, has observed a marked shift in client activity. What was once largely focused on Italian and European businesses expanding into the US, or families returning to Italy after long periods abroad, has increasingly become a steady flow of American individuals and families choosing to establish tax residency in Italy.”

“This trend appears to be driven primarily by quality-of-life considerations, and it shows no signs of slowing. The scale and pace of this migration is bringing with it a distinct set of technical challenges that are particularly acute in the Italian context. HNW and VHNW families commonly rely on trusts, especially US, Caribbean, or Channel Islands irrevocable trusts, as the foundation of their estate planning. While these structures are well understood and often lightly taxed in common law jurisdictions, Italy, like most civil law countries, has limited familiarity with them from a tax perspective. Although Italy is a signatory to the Hague Trust Convention, which facilitates formal recognition, interpreting common law trusts within the Italian legal and fiscal system presents unique challenges and leaves a significant degree of uncertainty for practitioners. This has become especially visible as more individuals arrive in Italy with pre-existing trust structures that were designed with very different legal assumptions in mind.”

“This arrival of capital has also increased demand among advisers for clear, workable guidance on how trusts should be classified, reported, and taxed in Italy. Fortunately, increasingly detailed guidance from the Italian tax authorities is beginning to address these issues, creating opportunities to restructure existing arrangements or design new ones that align with Italian rules while remaining coherent at an international level. For transnational families, this allows legitimate estate planning objectives to be preserved with greater predictability once Italy becomes the centre of their personal and financial lives.”

“From an Italian standpoint where we see more issues in succession is with Italian forced heirship rules. Italy has quite strict rules requiring each legitimate heir to receive an inheritance. This along with nearly every element, entity and individual in the strategy being in a different jurisdiction creates a lot of challenges.”

Rausch finishes by saying, “Although these Italian-specific incentives and evolving guidance help mitigate many of the uncertainties, the persistent overlay of US citizenship-based taxation and worldwide reporting obligations renders purely unilateral Italian planning insufficient. Even with a fully integrated US-Italy strategy, complications can still emerge, making truly effective outcomes dependent on tightly coordinated, bespoke planning.”

Steady flat tax increases – not a closed door

Stefano Loconte, Founding Partner, Loconte & Partners, Milan, who frequently appears on the Citywealth Top Italian advisors Lists, adds a thought on the recently increased fee applied to the flat tax regime. “A practical point for this update is that the flat-tax regime has been increased over time (to €200k in 2024, and then to €300k for new movers from 2026), which paradoxically can still work as a signaling device: Italy is effectively ‘pricing in’ certainty for UHNW rather than closing the door. From a market perspective, the theme is “priced certainty”: even with higher entry cost, the regime still offers a clear, administrable framework that can be easier to plan around than regimes in flux elsewhere.”

On forced heirship he adds a battle plan, “Mitigation is typically pursued through careful conflict-of-laws analysis, including the EU Succession Regulation, which (subject to its conditions) allows a choice of the law of nationality for succession planning, alongside coherent situs/asset mapping and robust contemporaneous documentation aimed at lowering litigation exposure rather than ‘bypassing’ mandatory rights.”

Coordinated US-Italy Planning for Effective Outcomes

Marco Sandoli, Partner, at LED Taxand a tax law firm based in Milan continues the discussion. “Yes, I agree, we see a trend of US persons considering Italy, particularly Milan. However, for US persons the ‘Italy tax location’ is never standalone: US citizenship-based taxation, reporting and structuring constraints remain central, so the decision often turns on net effective outcomes after US compliance and on succession planning impacts. The winning approach is a coordinated Italy-US plan, more so than for other countries, and it’s much more case by case.”

The flat tax regime is one of the main reasons wealthy Americans are eyeing Italy: it’s straightforward and appealing, especially when paired with the country’s great quality of life. But as Joshua S. Rubenstein explains, making it work smoothly still means coordinating carefully across borders and being extra mindful of how Italy views pre-existing trusts, plus its rules on community property and forced heirship.

Flat Tax Appeal and Key Considerations for UHNW US Clients

Joshua S. Rubenstein Partner, Global Chair, Private Wealth Department, Katten, a private client law firm based in New York, who advises on planning, administration and litigation under one practice, continues the thread. “We have also noticed an increased interest in moving to Italy among our UHNW US clients. The flat tax regime is extremely attractive, but so is Italy in general in terms of being a nice place to live. Pre-existing trust structures must be thought through carefully though, and advice needs to be taken on how Italy would regard them because Italy does not have trusts.”

“Another issue to be considered is that Italy has both community property and forced heirship. If the clients are retaining their US citizenship, this can be addressed by making an election of the property laws of a US state under Brussels IV: the European Succession Convention. But if the clients are expatriating (giving up citizenship), the community property and forced heirship regimes will have to be dealt with.”

Brussels IV is an EU law, effective since August 17, 2015, that harmonizes rules on cross-border successions across most EU member states. Community Property in Italy means property acquired during the marriage becomes owned 50/50 automatically unless there is an alternative formal agreement signed.

Interest in moving to Italy is not limited to ultra-high-net-worth clients and their estate planning concerns. Many other Americans are also relocating, drawn by family ties through jure sanguinis citizenship, affordable properties in southern Italy, or work in Milan, with tax options such as the flat rate for new residents and the 7% regime for foreign pensioners helping to make it viable.

From Italian Ancestry ‘jure sanguinis’ to Milan’s Business Hub

Marco Mesina Founder and Tax Lawyer at Move to Dolce Vita adds his view.“There is a very strong and growing trend of U.S. citizens relocating to Italy. The drivers are both structural and personal. A significant number of Americans are reclaiming Italian citizenship ‘jure sanguinis’ -where citizenship is acquired through parents or ancestors – and returning to the country of origin of their families, often after one or two generations in the United States.”

“Others, without Italian ancestry, are attracted by Southern Italy in particular, where high-quality seaside properties remain accessible by international standards and offer a compelling lifestyle proposition. U.S. individuals are generally aware that U.S. tax obligations continue to apply regardless of relocation; however, Italy offers effective mitigation tools such as the flat tax regime for new residents and the 7% tax regime for foreign pensioners.”

Mesina explains, “Milan represents a different but equally strong pull factor, attracting U.S. entrepreneurs, founders and senior executives. Business opportunities remain a key driver, but lifestyle, family roots and long-term quality of life are equally decisive factors behind this sustained migration trend.”

Mesina’s overview of relocation trends ties into wider lifestyle and fiscal reasons for U.S. interest in Italy, as outlined by other advisers.

Fiscal Incentives and Lifestyle Factors Fuelling American Interest

Guido Tizzanini, Senior Manager at EY Italy describes the various ways to migrate to Italy. “This growing interest from the US is often linked to the desire for a slower and more balanced lifestyle, supported by a cost of living that in many areas remains lower than in major U.S. or European cities, along with Italy’s cultural richness and mild climate. At the same time, several fiscal incentives introduced by the Italian government have played a significant role in attracting affluent individuals, professionals, and retirees, complemented by a set of immigration visas designed specifically for newcomers like the nomad visa program.”

“One of the well-known and most notable measures is the ‘flat tax’ on foreign-source income and assets, which places a cap on taxation of foreign income, without disclosing the full extent of one’s foreign wealth. In addition, Italy has introduced a regime for workers moving from abroad, allowing a substantial exemption on Italian employment and self-employment income for several years also applicable to home-office.”

“Lastly, Italy’s inheritance and gift tax which is capped at 8% also contributes to an overall tax environment that many Americans find appealing. Taken together, these factors make Italy an increasingly strategic choice for individuals seeking to get the most from their finances and a more grounded way of living.”

While tax and lifestyle factors make Italy appealing, there are also legal challenges for structures involving offshore trusts.

Tensions Between Offshore Trusts and Italy’s Forced Heirship Rules

Anthony Partridge Partner at law firm Ogier who specialises in tax and trusts, based in the Cayman offers a warning shot despite the many attractions. “One of the key issues we are seeing generally in Italy is the growing tension between irrevocable trust structures, often established in common law jurisdictions, and Italy’s forced heirship regime. While Italian law recognises foreign trusts under the Hague Trusts Convention, irrevocability does not necessarily shield assets from heirship claims if Italian reserved heirs can demonstrate that a trust infringes their mandatory entitlement.”

While Partridge flags the core legal tension, advisers like Rausch warn of growing uncertainty and expected court challenges in cases involving trusts used primarily for inheritance purposes.

Rising Uncertainty and Litigation Risks in Aggressive Trust Planning

Rausch adds a further view on this point.“There is increasing uncertainty for settlors and beneficiaries, particularly where trusts are used as succession planning vehicles rather than for genuine asset management purposes. We expect further litigation as heirs test the boundaries of enforceability, especially in cases involving aggressive trust planning. Milan is likely to remain at the centre of this debate, given its role as Italy’s financial hub and forum for complex cross-border disputes. There is a clear trend towards more cautious structuring, robust documented rationale for trust establishment, and, in some cases, a feeling that alternative planning solutions may be preferable to avoid future challenges.”

Partridge and Rausch outline the core tensions and expected court tests in Italy, but experts from offshore centres point to protective mechanisms in places like the Cayman Islands, where firewall laws aim to insulate trusts from foreign heirship rules, provided assets are not sited in the enforcing jurisdiction.

Firewall Protections and Asset Location Strategies in Cayman

Peter Goddard, Founder, IMG Trust Company offers a clarification from Cayman. “Forced heirship laws will usually apply to a deceased’s free estate, meaning the assets he or she owns in their own name, and not to assets of a trust in which the deceased is a beneficiary.”

“The laws of the trust’s jurisdiction will govern the application of any foreign forced heirship laws and, the Cayman Islands will not allow foreign forced heirship laws to override the terms of a Cayman Islands trust in relation to the disposition of most types of asset.”

“This ‘firewall’ legislation should protect trust assets from claims by those next of kin who stood to gain more under the forced heirship regime than they would under the trust the deceased settlor created. This protection is not complete though. If a trust holds assets that are situated in a foreign jurisdiction, then those assets will be vulnerable to the application of local forced heirship laws without regard to the trust. So, Italian real estate, bank and investment accounts and Italian company shares will all be vulnerable. This is why a well-crafted estate plan is necessary if the settlor wants to avoid the consequences of a forced heirship regime. Typically, the settlor will make provision out of non-trust assets in line with forced heirship laws but ensure that the trust only has assets that are outside that jurisdiction.”

These offshore mechanisms aim to insulate trust assets from foreign heirship claims where possible, yet specialists in Italy note the fundamental differences in succession systems and advocate for conflict-of-laws planning, proportionate allocations, and documented intent to minimise rather than eliminate challenges.

Planning to reduce rather than override risk – no magic bypass

Sandoli adds a further a sage view. “Italian forced heirship is structurally different from UK/US freedom of disposition, and that mismatch becomes highly relevant in cross-border families. Offshore trusts are useful asset management tools, but they won’t magically bypass Italian succession rules. If a trust appears designed to cut out protected heirs, Italian courts can challenge it. Mitigation is typically achieved through careful conflict-of-laws analysis (succession law, residence, situs of assets), coherent forum planning, proportionality in allocations, and strong contemporaneous evidence of intent and rationale, aiming to reduce litigation risk rather than override mandatory rules.”

These mitigation approaches address legal tensions in succession, but in family businesses, transitions are commonly prompted by sudden events rather than planned steps.

Transitions still frequently triggered by sudden and unexpected events

Alessia Allegretti, Partner, Boies Schiller Flexner who has long-standing experience in assisting foreign clients with the purchase and management of businesses and properties in Italy and who is is one of the three Founding Partners and Co-Managing Partner of the Italian offices, Milan and Rome, shares her thoughts. “On the point of succession and disruption in Italy, what I see most often is a combination of lack of preparation and communication. Family businesses should start planning succession well in advance, yet in practice transitions are still frequently triggered by sudden and unexpected events, such as the death or illness of the founder or current leader. When this happens, succession becomes reactive rather than managed.”

“Planning means ensuring that the transition is gradual and does not create discontinuity in day-to-day management. Postponing decisions tends to generate confusion, uncertainty and, ultimately, conflict. A transition needs to be actively managed, which requires preparation on both sides: the outgoing leadership and the incoming generation. A structured handover allows the next generation to gain legitimacy, while enabling the outgoing leader to retain a clear and meaningful role.”

Next Gen: Actively preparing for leadership

“Founders can gradually move from an executive position to a more advisory one, or act as ambassadors of family values and heritage, or as mentors to the next generation. This allows them to remain constructively involved, rather than abruptly sidelined. At the same time, the next generation must actively prepare for leadership. In my experience, it is essential that future leaders combine strong education with professional experience gained outside the family business, ideally in competitive environments and with exposure to international markets and corporate cultures. Only with this background can they return to the family enterprise with the credibility and skills needed to lead effectively.”

“Finally,” explains Allegretti, “effective succession requires clear and transparent communication within the family. Roles, responsibilities and decision-making criteria during the transition must be clearly defined to reduce misunderstandings and prevent conflict between branches of the family or across generations. In practice, successful leadership transitions in family businesses tend to rest on three key elements: early planning, clear role definition, and structured communication between those stepping out and those stepping in.”

Philanthropy as Legacy Tool: Foundations vs Trusts in Cross-Border Contexts

Allegretti finishes her points with a different theme. “Philanthropy is increasingly used not only for impact, but also as a legacy tool, particularly where families hold assets across borders. From an Italian law perspective, the primary philanthropic vehicle is the foundation. Foundations are commonly used for structured charitable activity, cultural initiatives and the long-term allocation of art collections. They offer stability, institutional recognition and continuity of purpose, but they are inherently rigid. Trusts with philanthropic or partially charitable purposes are, by contrast, a more flexible instrument. Trusts may be established in Italy as so-called internal trusts, while being governed by foreign law, since Italian law recognises trusts but does not provide for a domestic trust regime. This makes them particularly useful in cross-border contexts, but it also requires careful coordination with Italian succession rules and with the location and nature of the underlying assets.”

Tax-Free Import of Art Collections via Transfer of Residence Relief

Joshua S. Rubenstein adds a practical point on art mobility.“My experience is that it is relatively easy to move art collections to Italy, but relatively hard to move them out of Italy.”

Paolo Gaeta President & Ceo, Paolo Gaeta & Associati who has over thirty years of experience assisting private clients, specializing in wealth and financial planning, corporate governance, and trusts, adds his viewpoint, “The Italian legislation on philanthropy does not directly cover customs duties or VAT upon importation. However, new citizens moving to Italy can still achieve a tax-free entry for their collections through a different regulatory channel.”

“Under EU Customs Regulations on the transfer of residence, individuals relocating to Italy are exempt from import VAT and duties on personal effects, including art, provided they have owned the items for at least six months prior to the move. Therefore, the planning typically works in two stages: the client imports the collection tax-free using the transfer of residence relief and subsequently utilizes the philanthropic framework to contribute the assets to a foundation without incurring inheritance or gift taxes, ensuring long-term protection and unity of the collection.”

Philanthropic Foundations evolve from an elderly tool to an active strategy

Gaeta continues.“In the Italian landscape, a significant paradigm shift is underway with regard to philanthropy. Historically perceived as a legacy tool for the elderly or a way to honour the memory of a deceased founder, the philanthropic foundation has now evolved into a dynamic strategic asset for active entrepreneurs.”

“This change is partly driven by the recent reform of the Third Sector, which has drastically simplified the incorporation process: today, a foundation can be established with a simple notarial deed and a minimum capital of just €30,000, bypassing the lengthy government authorizations required in the past.”

“Consequently, we are seeing an increasing number of family businesses integrating foundations into their corporate structure early on. These vehicles now serve a dual purpose: they act as a bridge between the profit-oriented family business and the non-profit sector, enhancing brand reputation and implementing corporate welfare strategies, and, crucially, they function as a governance training ground. The foundation is becoming the preferred safe environment where the Next Gen can be tested and educated on board dynamics and responsibility before stepping into leadership roles within the main family enterprise.”

Philanthropy in Italy & Estate Planning for Art Collections

Alessandro Umberto Belluzzo, Barrister-at-Law, Founder & Equity Partner, Belluzzo International continues the discussion. “Navigating philanthropy and estate planning in Italy requires an understanding of the country’s civil-law framework, especially for families with art collections or philanthropic structures spread across multiple jurisdictions. Italy’s inheritance system built around forced-heirship principles, automatically reserve portions of an estate for close family members. This framework limits testamentary freedom and can complicate wealth transfers, particularly when philanthropic intentions or art-related bequests differ from the statutory distribution. For international families, especially those with ties to the UK, the US, Switzerland, or the UAE, structuring an estate that includes Italian assets requires a cross-border approach.”

“Philanthropic foundations, cultural purpose entities, and family charitable vehicles remain powerful tools, but they must be aligned with Italy’s rigid succession expectations. Foreign nationals, including Americans, have an important planning mechanism available through the EU Succession Regulation. This allows individuals to choose their national law to govern their estates within the EU, offering significantly greater flexibility in shaping philanthropic legacies and managing art collections. Still, this does not override all Italian constraints, and US-style trust arrangements may not automatically be recognised for Italian succession purposes.”

“Families often separate movable assets such as art from immovable Italian real estate and may house collections within specialised vehicles to ensure continuity, protection, and adherence to philanthropic objectives.”

Structured governance and clarity rather than tax reductions

Loconte adds a further viewpoint. “In Italy, philanthropy is increasingly used in estate planning as a governance and continuity tool, particularly for UHNW individuals holding significant art collections. The main objective is to avoid fragmentation among heirs and to ensure long-term preservation, professional management and coherent public or semi-public access. This is typically achieved through foundations or Third Sector entities with detailed statutes governing ownership, conservation, lending and succession of decision-making powers. Tax benefits arise mainly where donations support public-interest purposes, notably through the Art Bonus regime and the Third Sector framework, but the primary value lies in structured governance and clarity rather than tax reductions.”

Raul-Angelo Papotti, Partner at Chiomenti, Milan adds his perspective. “As of 1 January 2026, there is a complete set of beneficial tax provisions addressed to non-profit entities (“enti del terzo settore”) originally introduced in the Italian law framework in 2017. These are particularly effective for art collections, as Italy offers a favourable cultural and legal framework focused on preservation and continuity rather than fragmentation, with limited recurring direct and wealth taxation on art.”

Reduced VAT on sales and imports of works of art, antiques and collectibles to 5%

Papotti adds, “As of 1 July 2025, Italy has reduced the VAT on sales and imports of works of art, antiques and collectibles to a 5% rate (the lowest in the EU) extending this reduced rate to domestic sales by galleries, dealers and auction houses as well as imports, which can materially improve market fluidity and cross-border transfers. This lowers transactional costs and aligns the regime with other European markets.”

Addressing Forced Heirship: Limits of Offshore Trusts and Italian Mechanisms

Allegretti shares a further view. “Forced heirship remains a structural constraint for Italian families. The key point is to avoid viewing an offshore trust as a shortcut, as Italian forced heirship rules prevail regardless of the structure put in place. Of course, the testator has a free quota, and within that portion he or she is free to dispose of assets as desired. The only Italian instrument that allows forced heirship issues to be addressed in advance is the “patto di famiglia”. This mechanism allows the orderly transfer of a family business, or shares in a family company, to one or more descendants during the lifetime of the entrepreneur, with the consent of all forced heirs.”

“No contest” clause

Papotti adds a point. “A “no contest clause” is commonly included in trust deeds, stating that any beneficiary who initiates legal action to challenge the settlor’s estate or contests the provisions of the trust will forfeit their right to benefit from it. While this clause does not completely prevent legal disputes from arising, it acts as a deterrent, discouraging beneficiaries from pursuing such actions due to the risk of losing their benefits.”

Hybrid Strategies: Patto di Famiglia Combined with Offshore Trusts

More from Paolo Gaeta. “Mitigating the rigidity of Italian forced heirship requires a strategic focus on the settlor’s residence, which dictates the applicable succession law under EU regulations. The most effective approach to bridge the gap with Anglo-Saxon freedom of disposition is often a hybrid one: combining the Italian Patto di Famiglia to immunize business assets from inheritance disputes, alongside offshore trusts for financial wealth. This synergy creates a sustainable equilibrium, allowing the structure to withstand the test of time and effectively harmonizing Civil Law constraints with the flexibility of Common Law instruments.”

Private bank hits the news: Rejected proposal to acquire pure-play wealth manager Banca Generali 

Belluzzo explains the recent, high profile, rejected private banking deal in Italy. “Italy’s private banking sector has undergone significant shifts as assets under management continue to grow and competition intensifies. Against this backdrop, an important recent development was the failed attempt by a major banking group to acquire Banca Generali, one of Italy’s most prominent wealth‑management institutions. Despite strategic intent and alignment with broader consolidation trends in the European financial sector, the proposal was rejected by shareholders.”

Shareholder activism is strengthening

“The refusal of the acquisition underscores several structural dynamics within the Italian private‑banking environment. Shareholder activism is strengthening, prominent financial families retain significant influence, and strategic interests do not always align with institutional ambitions. At the same time, the rise in private wealth across Italy is pushing banks to scale their operations, expand advisory capabilities, and position themselves defensively against competitive and takeover pressures. As consolidation continues across Europe, private banking in Italy is becoming increasingly sophisticated, with leading institutions recognising that a strong wealth‑management arm is central to long‑term resilience.”

Loconte shares his view. “The rejection of Mediobanca’s proposed acquisition of Banca Generali reflects governance and strategic alignment constraints rather than a lack of confidence in the Italian private-banking market. The sector continues to grow, with assets under management increasing due to both net inflows and market performance. Italian private banks are responding by focusing less on asset gathering and more on absorbing complexity, strengthening advisory capabilities in cross-border structuring, alternative investments and succession planning, and investing in compliance, reporting and risk controls to support a larger and more sophisticated client base.”

Papotti offers his thoughts on the situation. “Quantitatively, the system is coping well with asset inflows. On the other hand, qualitatively, the challenge lies in meeting more complex client expectations. Clients increasingly require cross-border structuring, tax coordination and succession planning rather than pure investment management. As a result, Italian private banks are reinforcing advisory models and relying more heavily on external legal and tax advisors, shifting away from a purely product-driven approach.”

Conclusion

Italy’s growing appeal to US families is no longer driven by lifestyle alone. It reflects a more developed proposition that combines defined inbound tax regimes, a deeper advisory market and a clear policy intent to attract internationally mobile capital, decision makers and families.

The evidence throughout this article points to a structural reality rather than a promotional one. Italy’s civil law system, strict forced heirship rules and continuing complexity around trusts mean relocation cannot be approached in isolation. Effective outcomes depend on coordinated planning that aligns residence, asset location, family governance and succession objectives across jurisdictions.

Italy’s comparative strength lies not in simplicity, but in scope. It offers a large domestic market, a credible European financial centre, operating business opportunities and a mature private wealth ecosystem within a single EU jurisdiction. For US families willing to engage with its legal framework and plan deliberately, Italy can function as a stable long-term base rather than a lifestyle outpost.

The consistent message from advisers is clear. Italy works best where transparency, documentation and professional coordination are treated as foundations, not afterthoughts.

Italy update on crypto – part 2

While trusts, succession and family governance dominate much of the planning discussion, digital assets are increasingly part of the same picture. Italy’s decision to raise the tax rate on cryptocurrency gains to 33 percent from 2026, alongside a wider shift towards transparency and reporting, brings a newer asset class squarely into the private wealth framework. For internationally mobile families, crypto now raises many of the same questions as trusts and offshore structures: disclosure, control, succession and long-term coherence. These issues are examined in detail in the second part of this Italy update. Click here to read the crypto update.

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