Italy’s real estate market continues to attract international investors, but the success of an investment largely depends on its legal and tax structuring. This article outlines the main strategies adopted by foreign investors, including the use of Italian SPVs, international holding companies and structured financing. It also examines key issues such as permanent establishment risk, the applicable tax regime and governance mechanisms designed to ensure efficient management a

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