With Legislative Decree (LD) No. 139 of September 18, 2024 on “Provisions for the rationalization of the registration tax, inheritance and donation tax, stamp duty and other indirect taxes other than VAT”, article 3 par. 4-ter of Legislative Decree No. 346/90 is amended, which dictates the conditions for exemption from inheritance and donation tax for transfers of businesses or branches thereof, company shares and interests made in favour of the spouse and descen...
Changes to the taxation of non-UK domiciled individuals
Abolition of the “remittance basis” and the new “FIG” regime - Income tax and Capital gains tax (CGT)
Starting from 6 April 2025, the current “Remittance Basis” regime, available for non-doms, will be abolished and replaced by a new “Residence-based” regime, known as the Foreign Income and Gains (FIG) regime. The concept of domicile will no longer be relevant to UK taxation, and as a general rule, ...
"Change begins now” said Labour’s leader Keir Starmer, winner in the UK general election.
The new Labour government is set to implement in the coming months a series of fiscal policies to take effect from 6 April 2025 with the aim of rebalancing the budget deficit and encouraging economic growth, including:
Abolition of the resident non-domicile status: “non-dom" status refers to a person's tax status and describes a UK resident whose permanent home (“domicil...
The current wording of article 73, paragraph 3 of the Italian Tax Consolidated Act (hereinafter TUIR) (tax residence of companies and entities), as amended by Legislative Decree 209/2023 implementing the tax reform on international taxation, establishes that companies and entities are tax resident in Italy if they have in the territory of the State, for the greater part of the tax period:
(a) their registered office; or
(b) the place of effective manageme...
Overview
Most residential properties (dwellings) in the UK are owned directly by individuals. But in some cases a dwelling may be owned by a company or a partnership or other collective investment vehicle, whether UK resident or non-resident. In these circumstances the UK dwelling is said to be “enveloped” because the ownership sits within a corporate “wrapper” or “envelope”.
Chargeable Persons
The Annual Tax on Enveloped Dwellings (ATED) is a tax charged on “...
