Anyone arriving in Italy with assets spread across several countries faces, alongside the relocation itself, a change in the rules governing taxation, succession and asset protection. Planning in advance makes it possible to protect and organise what you own. Below we cover the risks, the available tools and how to build a tailored strategy.
Protecting your assets when relocating: why it matters
For a family or an individual with significant wealth, relocating to Italy is a moment in which many points of reference change at the same time: tax residence, the law applicable to certain relationships and exposure to a new legal system. For this reason, protecting assets when moving to Italy is not an optional extra, but an essential part of the preparation.
Protection, in this context, has a dual meaning. On the one hand, it means shielding assets from future risks, such as third party claims, disputes or unexpected events. On the other, it means organising wealth in an orderly and efficient way, so that its management, its transfer to heirs and its taxation are clear and manageable.
The strength of those who plan lies in timing. Many protective choices, in order to be effective and not open to challenge, must be made when the asset position is still calm and no claims are pending. Addressing them at the time of relocation, when the entire position is in any event being reviewed, is natural and efficient.
There is also a cultural reason. Those coming from another legal system bring with them instruments and practices that do not always correspond to Italian law. Understanding which protections the Italian system offers, and how they connect with those of the country of origin, is the first step in avoiding a planning gap precisely at the point of transition between two worlds. Relying on professionals familiar with both legal systems makes it possible to close that gap from the outset.
The risks of holding assets in several countries
Holding assets spread across several countries is typical of those who lead an international life, but it carries specific risks that should be understood. The first is fragmentation: accounts, real estate, shareholdings and investments located in different jurisdictions follow different rules, currencies and compliance requirements, and managing assets in several countries without unified coordination can create inefficiencies and omissions. Consider a family with a home in Rome, a property in the Emirates and a package of corporate shareholdings abroad: three assets, three legal systems, three tax regimes, and no single picture holding them together. Added to this is the difficulty of having, at all times, an updated and complete overview of one’s wealth.
A second set of risks is tax related. The same asset or income may fall within the taxing powers of more than one State, with the risk of double taxation, and the new resident in Italy is required to declare foreign assets, failing which penalties may apply. Transparency between tax authorities is now highly developed, making any omission easily detectable.
There is also the succession risk, which is often underestimated. When heirs and assets are located in different States, different succession laws may come into play, with rules of distribution and forced heirship shares that do not coincide, and absent or inconsistent planning may result in disputes and high costs when wealth is transferred.
Finally, the dispersion of wealth creates management risks: difficulty coordinating advisers in different countries, duplicated costs and a lack of overall vision. Recognising these risks does not mean giving up an international presence, but approaching it consciously, transforming a fragmented structure into a coherent and controlled system. A periodic mapping of assets is the prerequisite for any effective protection.
Protection and planning tools
Italian law offers several asset protection tools for foreign nationals relocating to Italy, each with its own function. The choice depends on the objectives: family protection, segregation of certain assets, generational transfer, management of shareholdings. Understanding their functions helps avoid adopting unsuitable or, worse, ineffective solutions.
Among civil law tools, the family fund allows certain assets to be allocated to meeting the needs of the family, limiting their exposure to debts unrelated to those needs. The trust, an institution recognised in Italy under the Hague Convention, allows assets to be segregated by entrusting them to a trustee for the benefit of beneficiaries or for a specific purpose, creating a separate estate distinct from both the settlor and the trustee.
For business succession, the family agreement allows an entrepreneur to transfer the business or shareholdings to one or more descendants, managing succession in advance and settling the rights of the other forced heirs. The deed of destination, in turn, binds real estate or registered movable assets to the pursuit of interests worthy of protection, with effects enforceable against third parties through registration.
None of these tools, it must be said clearly, allows assets to be removed from legitimate creditor claims or to prejudice the rights of forced heirs: protection operates within the limits of the law. For this very reason, their effectiveness depends on correct and timely planning, identifying the right instrument for each objective and avoiding standardised solutions. This is also why their design should be entrusted to qualified professionals, and not to models replicated without adapting them to the specific case.
Coordinating personal and business assets
For those who are also entrepreneurs or hold shareholdings, one of the most important needs is to keep personal and business assets separate, while coordinating them properly. Confusion between the two spheres is one of the main sources of risk, because it exposes personal assets to business events and vice versa. Clearly separating what belongs to the individual from what belongs to the business is the first safeguard.
The classic organisational tool is the holding company, a company that holds shares in the various businesses and allows them to be managed in a unified way. Through this type of structure it is possible to separate ownership from operational management, centralise governance, plan flows and prepare generational transfer in an orderly manner.
A holding company, however, is not an abstractly valid solution. Its suitability depends on the composition of the assets, the nature of the activities and the domestic and international tax profiles involved. For those arriving from another country, it is also necessary to verify how the structure connects with any companies or vehicles already existing abroad. Its adoption must therefore always be preceded by a careful analysis of costs and benefits.
Coordination between personal and business assets therefore requires a perspective that brings together company law, succession profiles and taxation. This is where planning shows its value, because it makes it possible to protect the family without immobilising the business, and to allow the business to grow without exposing personal wealth to unnecessary risks.
Tax aspects not to underestimate
No protection strategy is complete without careful assessment of tax aspects. The first concerns wealth taxes and monitoring obligations: the new resident must declare foreign accounts, real estate and investments and, in some cases, pay the relevant taxes on the value of assets held abroad. Neglecting this aspect can undermine, from an economic perspective, a plan that is otherwise impeccable.
A second aspect concerns the taxation of transfers. Inheritance and gift tax, reorganised by the reform in force from 2025, applies to the transfer of wealth with rates and allowances that vary according to the degree of kinship. For residents, it concerns assets wherever located; for non residents, only assets located in Italy. Planning in advance means knowing the impact of this tax in advance.
There is also the taxation of protection tools. Trusts, holding companies and other vehicles have their own tax treatment, which affects their actual convenience and must be assessed both in Italy and in the countries involved. A solution that is advantageous under civil law may prove costly from a tax perspective if not properly structured. The tax assessment must therefore be carried out in parallel with the civil law assessment, and not after decisions have already been made.
Finally, those transferring their residence may access favourable regimes designed for new residents, which significantly affect the taxation of foreign income and certain compliance obligations. Including these regimes in the protection strategy makes it possible to optimise the overall framework, provided that their requirements and compatibility with the other instruments adopted are carefully verified.
How to build a tailored strategy
All of this shows that there is no solution valid for everyone: the protection of international wealth in Italy must be built to measure, starting from the concrete situation of the individual and the family. The first step is a complete picture, mapping assets, income, countries involved, family structure and objectives.
On the basis of this analysis, priorities are identified: protecting the family home, safeguarding the business, organising the transfer to heirs, optimising taxation. Each objective corresponds to the most suitable instrument, or combination of instruments, calibrated to avoid both insufficient protection and excessive, unnecessary complexity. The right measure is the one that protects without overburdening, chosen according to the value and nature of the assets.
A decisive element is coordination among professionals, and this is precisely the role we take on as a firm. The matter touches civil, corporate, tax and international law: for each client we bring into dialogue the lawyer who frames the position, the notary who drafts the deeds, the accountant who calculates the tax effects and, on the foreign side, the advisers in the country of origin. We hold the direction of this work ourselves, so that the choices come together in a single design, without inconsistencies or duplication, and the client has one point of contact answering for the whole.
Finally, a tailored strategy is not static: it must be reviewed over time, as asset, family and regulatory circumstances change, and a periodic review, at least whenever a significant change occurs, keeps it aligned with reality. Because protecting wealth built over a lifetime is not about raising a wall, but about drawing a design that crosses borders with the same care shown by the person who created that wealth: this is the difference between owning assets in several countries and truly having control of them.
