Alessandro Borsetto
(+39) 02 3663 8610
Private Tax
LEXIA provides highly specialized tax services to individuals and families with complex estate, focusing on estate planning, international tax matters, and full compliance with both Italian and foreign tax regulations. Our goal is to manage, protect, enhance, and efficiently transfer wealth in a fully compliant and tax-efficient manner.
We offer tax advice in all key areas of individual taxation, including entrepreneurs and professionals. Our tax services are delivered through a multidisciplinary approach and close collaboration with our Wealth Management & Trust, Real Estate & Property Management and Private Tax teams.
Expertise in Italian favourable tax regimes for individuals and international taxation
We assist clients in tax planning: in the evaluation of their tax residence, in dealing with taxation of foreign-sourced income and assets, always in compliance with double tax conventions (if in force) and with reporting obligations.
LEXIA has gained significant experience in assisting individuals for the option of Italy’s special tax regimes, including the “new residents” regime (payment of an annual flat tax on foreign income, equal to €300,000), the “impatriates” regime for individuals who work in Italy for most of the tax year and transfer their residence there (under certain conditions), and the “retirees” regime for recipients of a pension from a non-Italian social security fund who transfer their residence to one of the municipalities in Southern Italy (payment of a 7% substitute tax on foreign-source income).
Managing ordinary and extraordinary tax compliance
We handle the filing of income tax returns, including sections related to foreign-held assets (Forms RW, RM, RT), we assist our clients with supporting documentation, and ensure compliance with all ancillary requirements. For clients with VAT numbers, we offer accounting, VAT management, periodical filings, and statutory bookkeeping services.
Inheritance and Gift taxes
We provide tax advice on the transfer (mortis causa/inter vivos) of assets and rights (of any kind: real estate, shareholdings, etc.), located in Italy or abroad, in compliance with Italian and foreign legislation.
Trusts
We provide tax advice on domestic and foreign trusts, with particular attention to the tax aspects related to the life of the trust (transfer of assets and rights into the trust, distribution of assets and rights to beneficiaries, transactions carried out by the trustee), including cross-border contexts.
Real estate
We also offer assistance in handling the payment of IMU (property tax) for properties held in Italy and IVIE (property tax for properties held abroad) for those held abroad, taking care of both the calculation and the filing and submission of tax declarations.
Works of art and collectibles
We provide tax advice on the transfer of works of art and collectibles, taking into account their specific nature and the special provisions of tax law.
- Annual substitute tax: €300,000 on all income from foreign sources, regardless of its amount, for individuals who transfer their tax residence to Italy from 1 January 2026 (Law no. 199/2025). For earlier transfers, the amounts of €200,000 (after 10 August 2024) or €100,000 continue to apply. Income from Italian sources remains subject to ordinary taxation.
- Family members: the regime can be extended to each family member for an additional annual amount of €50,000 (€25,000 for earlier transfers).
- Requirements and option: not having been resident in Italy for at least 9 of the 10 preceding tax years. A ruling request (interpello), optional but recommended, may be submitted, and the Italian Revenue Agency replies within 90 days. The option is exercised in the tax return for the year of transfer (or the following year) and the tax is paid in a single instalment by the balance payment deadline for income taxes (30 June).
- Cherry picking: income from one or more foreign States can be excluded from the regime and is then taxed ordinarily in Italy, with a credit for taxes paid abroad.
- Other effects: foreign assets are exempt from tax monitoring (RW form), IVIE and IVAFE, and gifts and inheritances of foreign assets are exempt from inheritance and gift tax. Capital gains on qualifying shareholdings realised within the first 5 years are, however, taxed ordinarily (26%).
- Duration and termination: up to 15 years. The regime can be revoked at any time with no recovery of tax for previous years, whereas failure to pay or partial payment results in forfeiture, with no possibility of opting for it again.
Other practices
LEXIA supports Italian companies and multinational groups in every aspect of corporate taxation—from extraordinary transactions such as mergers, demergers, and acquisitions, to the establishment of joint ventures and holding companies. Our services include feasibility analysis, tax due diligence, and assistance in dealings with tax authorities, ensuring security and efficiency in complex operations.
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LEXIA assists companies operating in international contexts in designing and implementing transfer pricing policies compliant with the arm’s length principle. Our services include functional analysis, selection of the most appropriate methodologies—such as cost-plus or uncontrolled comparables—and the use of benchmarking databases, in line with OECD guidelines and best international practices.
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The firm, with a dedicated team, provides legal advice and assistance to companies, entrepreneurs, and individuals operating in the business world.
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We provide consultancy and assistance with business crisis in order to resolve disputes and mitigate the impact of a business crisis or tax debt. LEXIA's team protects the client's interests, ensure compliance with relevant laws, and work towards favorable resolutions to address financial difficulties.
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We provide comprehensive tax advisory services, assisting our clients on tax matters related to their commercial and strategic projects, and ensuring highly qualified and up-to-date support on the complex national and international tax environments. Our team of experts collaborates closely with professionals from the corporate and financial law departments, ensuring an integrated approach that meets business needs and optimizes their tax structures efficiently and in compliance with applicable regulations.
Moreover, we offer specialized tax advice to high-net-worth individuals, supporting them in all tax law matters related to the transfer of tax residence to or from Italy. This includes tax optimization for entering or leaving the country, ensuring compliance with both Italian and foreign regulations for personalized and strategic tax planning.
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LEXIA boasts a high and well-established level of specialization in tax law, thanks to dedicated internal departments (tax, tax enforcement, tax advisory, administrative law, and public finance), all skillfully led and coordinated by cofounder and managing partner Avv. Prof. Alessandro Dagnino, one of the most renowned and respected tax lawyers at the national level.
We have a long series of innovative case histories that have impacted tax law and business, with cases also handled before the Court of Cassation and the Constitutional Court. We provide consultancy and assist clients in all phases of the tax assessment procedures conducted by the Italian Revenue Agency and/or the Guardia di Finanza.
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