International Taxation

A holding company isn't just a container for shareholdings. It's a center for managing capital, corporate decisions, and asset flows. In an international context characterized by investment mobility, tax transparency, and a growing focus on economic substance, its function cannot be reduced to mere tax efficiency.

Foreign investment doesn't just concern companies formally incorporated abroad. It more fundamentally concerns the relationship between a company's declared headquarters and the place where decisions are actually made. In a context of increasing tax transparency, administrative cooperation, and attention to economic substance, governance has become a tax variable.

International mobility no longer concerns only large multinational corporations or managers seconded abroad. It concerns entrepreneurs, professionals, wealthy families, investors, beneficiaries of inheritance structures, shareholders, and individuals who live, work, and invest across multiple jurisdictions. In this scenario, tax residency cannot be treated as a formal requirement to be settled a posteriori.

Tax & Wealth Perspectives is a LEGEX analytical platform dedicated to the legal interpretation of economic trends. The newsletter explores international taxation, wealth governance, cross-border investments, global capital flows and geopolitical scenarios through an integrated approach. In a context shaped by economic fragmentation, increasing State intervention and greater mobility of wealth, law becomes an essential instrument for understanding and ordering global complexit

The article examines how international investors can structure investments in Italy through European holding companies. It outlines the main strategic and tax advantages, including the application of the EU Parent-Subsidiary Directive, the treatment of dividends and capital gains, and the role of double tax treaties. Particular attention is given to substance requirements and governance issues in cross-border investment structures.

International Investment Asset protection and new tax challenges in the post-CRS global context