Application of IVIE for property abroad when the Trust is sham

The Italian income revenue authority (Agenzia delle Entrate) explained by means of circular n. 28 issued the 2nd of July 2012 that, if an estate is owned by a domestic or foreign Trust, when it is a sham Trust made by an individual resident in Italy, the last one is the tax subject for IVIE – the Italian tax on the value of the property situated abroad. (the text of circular is  available only in Italian, for any further information please write us: info@mpotrustee.it