Italy grants first successful non-dom status application to former UK non-dom

Italy has granted the first successful application for non-dom status following the introduction of a favourable tax regime for non-domiciled residents earlier this year.

The regime aims to attract investment to the country by offering newly tax resident individuals in Italy a yearly substitute tax of €100,000 (€25,000 for each additional relative) on foreign-sourced income, instead of taxing income on a worldwide basis. To qualify, individuals must have been non-tax resident in Italy for at least nine out the 10 years preceding their transfer to the country. The regime is valid for 15 years.

The first individual to have been granted non-dom status was represented by Withers. The firm said that the high net worth individual was previously registered as a non-dom in the UK, and decided to move to Italy “to take advantage of the new status and to establish a new hub for his family”.

Head of the Withers Italian tax team Giulia Cipollini, said: “Our client has been non-tax resident in Italy for the past nine years and owns assets and investments around the world and has been the director of several non-Italian companies. He is a great illustration of how the Italian res non-dom scheme can be extremely attractive for internationally mobile individuals and we’re delighted to have been able to secure the first approved non-dom application.”

The move comes as changes to the UK non-dom regime are scheduled to take effect from 6 April 2017, with a transitional window in place until April 2019. The changes include deeming non-domiciled individuals who have been resident in the UK for 15 out of the previous 20 years as domiciled for income tax and capital gains tax, and applying inheritance tax to UK residential property owned by offshore structures.

The changes were removed from the Finance Bill this year ahead of the General Election, but were reintroduced last month. The announcement was met by disapproval from many in the accounting industry, including partner at Blick Rothenberg Nimesh Shah.

He said: “After the hard work to establish the draft legislation, it was unprecedented to then remove the provisions in the wake of the General Election announcement, in order to rush through the Finance Bill before Parliament was dissolved.

“The entire legislative process around the non-domicile reforms has been shambolic, since the original announcement by George Osborne two years ago. There have been constant delays leaving taxpayers uncertain about what action they needed to take, leaving important decisions to be made to the last minute.”

“When the legislation was unexpectedly removed before the General Election, this meant an uncertain period for non-domiciled individuals on whether the action they had taken to plan for the changes could leave them out-of-pocket. It also meant that some taxpayers had put their plans on hold before taking any action,” he added.

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