When faced with a request for information from the tax authorities, it is crucial to act promptly. Regularization cases can be particularly complex and time-consuming, especially due to the administration's right of reassessment.

The nearly immediate transfer of dividends to its sole shareholder and the lack of significant economic activities by the parent company strongly indicate the absence of beneficial ownership.

The October issue of Ingénierie Patrimoniale (Journal of Wealth Engineering - JFA) features an in-depth article by Sandro Assogna, lawyer and founder of TaxLhab, on Italy's new optional early payment regime for inheritance and gift tax (ISD), effective from 2025 on asset transfers from trusts.

The tax regime for impatriates is a great opportunity for companies in France looking to attract international talent. This system allows impatriate employees and executives to benefit from significant tax exemptions on their income for a maximum period of eight years.

An important decision regarding the application of the Contribution exceptionnelle sur les hauts revenus (CEHR) on French-sourced dividends paid to an Italian resident

Italy offers a favorable tax regime for retirees who decide to transfer their tax residence to the country, aiming to attract investments, stimulate consumption, and bring resources to the southern regions. This regime allows for a substitute tax of 7% on foreign income for a maximum duration of 9 years.

The most significant novelty of the reform is the introduction of an optional regime of advance taxation at the time of the transfer of assets to the trust or the opening of the estate.