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.

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