“Reversionary” trusts with fixed taxes

When the trust allocates assets to the settlor, it is referred to as a ‘reversionary’ trust: this would typically occur in the case of a blind trust, in which the reversion of the assets to the settlor is foreseen from the origin, or when the settlor is the final beneficiary of the trust or subsequently becomes one.

In these cases, as also stated by case law (Cassation 8719/2021) and by practice (Ruling 106 and 352/2021), only fixed taxes (registration, as well as mortgage and cadastral taxes when real estate is involved) apply to the reversion.

Dario Augello and Paolo Giovannini analysed this matter in the article “Reversionary trusts subject to fixed taxes” on Eutekne.

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