Family Office in Italy: Rules, Costs and Tax in 2026
Italy has no family office regime: no family office licence or definition was found, and the Consolidated Law on Finance (TUF) reserves investment services provided professionally to the public to authorised firms such as SIMs, banks and SGRs. People who move their tax residence to Italy from 1 January 2026 can opt to pay a flat EUR 300,000 a year on foreign income (EUR 50,000 for each family member included) for up to 15 years, and inheritance tax for the spouse and direct-line relatives is 4% on the part above EUR 1 million per heir. A 2022 study by Politecnico di Milano and the Free University of Bolzano, reported by FocusRisparmio, counted 178 family offices serving Italian families, 169 of them active in Italy. [1, 2, 3, 4, 5, 6]
Best for: Wealthy individuals moving to Italy who want a fixed annual tax on foreign income (EUR 300,000 a year for those arriving from 2026, for up to 15 years) and families planning to pass a business to descendants under the 4% inheritance tax above EUR 1 million per heir and the exemption for transfers of businesses and controlling stakes.
At a glance
| Licence | No family office licence found; TUF reserves investment services to the public (reported) reported |
|---|---|
| Minimum wealth | No wealth minimum in the rules checked; no family office regime |
| Who counts as family | No legal definition; flat tax extends to Civil Code art. 433 relatives (reported) reported |
| Serving several families | No MFO licence; investment services to the public need a SIM, bank or SGR (reported) reported |
| Law and courts | Civil law: Civil Code, TUF for finance, EU directives; national taxes (reported) reported |
| Substance | No official figure found |
| Holding vehicles | SpA, SapA, Srl; patto di famiglia; Hague Trust Convention in force since 1992 (reported) reported |
| Corporate tax | IRES 24% plus IRAP 3.9% standard; regions vary IRAP by up to 0.92 points (reported) reported |
| Family office tax | No regime; 95% dividend and gains exemptions need 5% or EUR 500,000 stakes (Law 199/2025) reported |
| Personal income tax | IRPEF 23% to 43% (2026); 2026 arrivals can opt for EUR 300,000 a year on foreign income reported |
| Inheritance tax | 4% above EUR 1 million per heir for spouse and direct line; 6% or 8% others (reported) reported |
| Wills and succession | Forced heirship: children 1/3 to 2/3, spouse 1/4 to 1/2; patto di famiglia (reported) reported |
| Residence | Investor Visa from EUR 250,000 (start-up) to EUR 2 million (bonds); elective residence |
| Time to set up | No official figure found |
| Official fees | No official figure found |
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Licence and who qualifies
How is a family office licensed in Italy?
No family office licence, registration or exemption was found. Article 18 of the TUF reserves the professional provision of investment services and activities to the public ('nei confronti del pubblico') to SIMs (investment firms), EU investment firms, Italian and EU banks and third-country firms, and lets authorised SGRs (asset management companies) provide the services in article 1(5)(d), (e) and (f); recital 7 of the EU AIFM Directive says family office vehicles that invest the private wealth of investors without raising external capital should not be considered alternative investment funds. No official text was found that says whether a single family office managing only its own family's assets falls inside the article 18 reserve; the TUF was read on Brocardi.it (updated to 7 August 2026). [1, 8]
Reported by the sources named, not confirmed by an official source.
What is the minimum wealth for a family office in Italy?
No minimum family wealth in the rules checked: there is no family office regime, the reserve in article 18 TUF turns on providing investment services professionally to the public, and recital 7 of the AIFM Directive turns on whether external capital is raised; neither sets a wealth figure. The fixed amounts found for wealthy families are tax and residence figures, not family office tests: the EUR 300,000 a year flat tax for new residents and the Investor Visa thresholds (see personal tax and residency). [1, 2, 8, 9]
Who counts as family?
No legal definition of 'family' for a family office was found, because there is no family office regime. Other rules use their own circles: the new residents' flat tax can be extended to the family members listed in article 433 of the Civil Code (article 24-bis(6) TUIR), the inheritance tax exemption for business transfers covers descendants and the spouse, and a patto di famiglia transfers a business or shareholdings to one or more descendants. [3, 7, 10]
Reported by the sources named, not confirmed by an official source.
Can one office serve several families?
No dedicated multi-family office licence was found. Under article 18 TUF, providing investment services and activities professionally to the public is reserved to SIMs, EU investment firms, Italian and EU banks and third-country firms; authorised SGRs may provide the services in article 1(5)(d), (e) and (f), and financial intermediaries on the register in article 106 of the Banking Law may provide some services set by the Bank of Italy after consulting Consob. Registration routes for independent financial advisers (OCF register) were not checked. [1]
Reported by the sources named, not confirmed by an official source.
Law, substance and vehicles
Which law and courts apply?
Italy is a civil-law country: succession, forced heirship and the patto di famiglia are set out in the Civil Code (codice civile), investment services are governed by the Consolidated Law on Finance (TUF, Legislative Decree 58/1998), and as an EU member state Italy is bound by EU directives such as the AIFM Directive. Income taxes are national (IRPEF for individuals, IRES for companies), with regional and municipal surcharges on IRPEF and regional variation of IRAP, according to PwC. The Civil Code and TUF were read on Brocardi.it, a private legal database, because normattiva.it could not be opened. [1, 5, 8, 10, 11, 12]
Reported by the sources named, not confirmed by an official source.
What substance is required?
Not found in official sources. No office, staff or spending rule for a single family office was found in the sources opened, and the organisational requirements for SIMs and SGRs were not checked.
Which holding vehicles are available?
EC News (2018) lists the resident companies covered by the inheritance tax exemption for business transfers as the SpA (company limited by shares), SapA (partnership limited by shares), Srl (limited liability company), cooperatives and mutual insurance companies, and a patto di famiglia is a contract by which an entrepreneur or shareholder transfers a business or shareholdings to one or more descendants (Civil Code, article 768-bis). Italy is a party to the Hague Convention on the law applicable to trusts and on their recognition, in force for Italy since 1 January 1992 (HCCH status table), and since 1 January 2025 the inheritance and gift tax law expressly covers transfers from trusts and other vincoli di destinazione (article 4-bis TUS, added by Legislative Decree 139/2024). The società semplice and foundations were not checked in a source opened. [7, 10, 13, 14]
Reported by the sources named, not confirmed by an official source.
Tax
What is the corporate tax rate?
IRES (corporate income tax) is 24% and IRAP (regional tax on productive activities) is 3.9% at the standard rate, which regions may change by up to 0.92 percentage points; a reduced 20% IRES rate applied for FY 2025 only, under conditions, to companies reinvesting profits (PwC, last reviewed 13 July 2026). No change to the 24% IRES rate was found in the 2026 Budget Law (Law 199/2025). PwC says different IRAP rates apply to banks, financial entities and insurers and special rules to holding companies, and Law 199/2025 (article 1(74)) raises the IRAP rates in article 16(1-bis)(b) and (c) of Legislative Decree 446/1997 by 2 percentage points for the tax period after the one in progress on 31 December 2025 and the next two, except for the entities in article 6(2), (3), (4) and (9) of that decree. A holding company pays IRES, with the dividend exclusion and participation exemption described under family office tax. [2, 12]
Reported by the sources named, not confirmed by an official source.
Are there tax incentives for family offices?
No tax regime specific to family offices was found. For a holding company, 95% of dividends from companies not resident in tax havens is excluded from IRES, and capital gains on shareholdings are 95% exempt if they were held for at least 12 months, classified as financial fixed assets, and the subsidiary carries on a commercial activity and does not earn most of its income in a tax haven (PwC). Law 199/2025 (article 1(51) and (54)) adds that both apply only to a direct holding of at least 5% of capital or with a tax value of at least EUR 500,000, counting holdings held indirectly within the same group, for distributions resolved from 1 January 2026 and for gains on disposals of shares and holdings in companies (the law gives no separate start date for these gains). [2, 15]
Reported by the sources named, not confirmed by an official source.
Is there personal income tax?
IRPEF for 2026 is 23% up to EUR 28,000, 33% from EUR 28,000 to EUR 50,000 and 43% above EUR 50,000 (PwC), after Law 199/2025 cut the middle rate from 35% to 33%; regional surcharges generally range from 1.23% to 3.33% and municipal surcharges from 0% to 0.9% (PwC). People who move their tax residence to Italy after at least nine of the previous ten years abroad can opt for a flat substitute tax on foreign income of EUR 300,000 a year, plus EUR 50,000 for each family member included, if they move from 1 January 2026 (Law 199/2025); people who moved earlier keep EUR 200,000 (those who moved after Decree-Law 113/2024 took effect in August 2024) or EUR 100,000, with EUR 25,000 per family member. The option ends after 15 years and does not cover gains on qualified shareholdings realised in the first five years. Article 24-bis(3) TUIR (read on Brocardi.it) says the option is exercised after a favourable reply to a ruling request (interpello), while the Revenue Agency's page (2023) says the taxpayer 'can' file one and PwC (July 2026) calls a ruling 'generally advisable'; PwC says the regime also replaces the wealth taxes on foreign real estate and financial assets and foreign asset reporting. [2, 3, 5, 16]
Reported by the sources named, not confirmed by an official source.
Is there inheritance or estate tax?
Italy levies inheritance and gift tax on the net value received: 4% for the spouse and relatives in the direct line on the part above EUR 1,000,000 per beneficiary, 6% for brothers and sisters on the part above EUR 100,000 each, 6% for other relatives up to the fourth degree and certain in-laws with no allowance, and 8% for others; for a beneficiary with a recognised severe disability (article 3(3) of Law 104/1992) only the part above EUR 1,500,000 is taxed (article 7 of Legislative Decree 346/1990 as replaced by Legislative Decree 139/2024, with effect from 1 January 2025; PwC gives the same rates for inheritance and gift tax and says the tax has been self-assessed since 1 January 2025). Transfers to descendants and the spouse, including by patto di famiglia, of businesses, company shares and holdings are exempt: shares in resident companies (article 73(1)(a) TUIR) only if they give or add to control and control is kept for at least five years, businesses if the recipients carry on the business for at least five years, and other company shares if they are kept for five years; the recipients must declare this commitment, and the rule also covers companies resident in the EU or EEA or in countries with an adequate exchange of information (article 3(4-ter) as amended by Legislative Decree 139/2024). Transfers from trusts are taxed when they pass to the beneficiaries, at the rate and allowance for the settlor-beneficiary relationship, unless the settlor opts to pay when assets are contributed (article 4-bis); mortgage and cadastral taxes on inherited real estate were not confirmed in an official source (see note). [4, 7, 17]
Reported by the sources named, not confirmed by an official source.
Succession and residence
How do wills and succession work?
Italy has forced heirship (legittima): the spouse, children (including adopted children, and descendants who inherit in their place) and ascendants are protected heirs (Civil Code, article 536). A single child is reserved half of the estate and two or more children two thirds (article 537); a spouse alone is reserved half, plus the right to live in the family home and use its furniture (article 540); with one child, the child and the spouse are each reserved a third, and with more children the children share half and the spouse a quarter (article 542). A patto di famiglia lets an entrepreneur or shareholder transfer a business or shareholdings to descendants during their lifetime: the spouse and all other future forced heirs must take part and be paid the value of their shares unless they waive it, and what is received is not subject to collation or reduction (articles 768-bis and 768-quater; Civil Code read on Brocardi.it). [10, 11, 18, 19, 20, 21]
Reported by the sources named, not confirmed by an official source.
Can the family get residence?
The Investor Visa for Italy (Law 232/2016) is for non-EU nationals who invest at least EUR 2 million in Italian government bonds with a residual maturity of at least two years, EUR 500,000 in a joint-stock company or EUR 250,000 in an innovative start-up on the official list, or donate at least EUR 1 million to a public-interest project (Embassy of Italy in Pretoria, May 2024). The investment must be made within three months of arrival and kept for the whole permit: the investor gets a 2-year permit renewable for 3 years at a time, family reunification under general immigration law covers a spouse over 18 and minor children (and some dependent adult children and parents), and after five years of regular residence the holder may apply for an EU long-term residence permit (Investor Visa for Italy portal and FAQ). The Embassy in Pretoria says the programme is suspended for Russian and Belarusian citizens, including people who also hold another citizenship. People with stable income not from employment, such as pensions or property, can instead get an elective residence visa, which needs about EUR 31,000 a year (per person, according to the New York consulate) and a home in Italy, can be issued to a dependent spouse, minor children and dependent adult children living with their parents, and does not allow work (Italian consulate in New York, embassy in Ankara). [9, 22, 23, 24, 25, 26]
Time and fees
How long does set-up take?
Not found in official sources.
What are the official fees?
Not found in official sources. No family office licence fee exists because no family office licence was found; no official fee schedule for registering an SpA or Srl, or for SIM or SGR authorisation, was opened.
Pros and cons
Pros
- People who move to Italy from 1 January 2026 after at least nine of the previous ten years abroad can pay a flat EUR 300,000 a year on foreign income (EUR 50,000 per family member included), for up to 15 years.
- Inheritance tax for the spouse and direct-line relatives is 4% only on the part above EUR 1 million per heir, and transfers of businesses and controlling stakes to descendants and the spouse can be exempt if the business is carried on or control is kept for five years (reported).
- The Investor Visa gives a 2-year permit, renewable for 3 years at a time, from EUR 250,000 in an innovative start-up or EUR 500,000 in a joint-stock company, with family reunification and EU long-term residence possible after five years.
Cons
- There is no family office regime: no official text says whether a single family office is outside the TUF reserve, and investment services provided professionally to the public need a SIM, bank or SGR.
- Forced heirship reserves a third to two thirds of the estate for children and a quarter to a half for the spouse, and a patto di famiglia needs the spouse and all other forced heirs to take part.
- Under Law 199/2025 the 95% dividend exclusion (for distributions resolved from 1 January 2026) and the participation exemption need a holding of at least 5% of capital or a tax value of at least EUR 500,000, and the top IRPEF rate is 43% plus regional and municipal surcharges.
