close
Share with your friends

Italy: Tax-exemption requirements, proceeds from real estate investment funds

Italy: Tax-exemption requirements, real estate

The Italian Revenue Agency issued two “statements of practice” in the form of tax rulings that describe the tax-exemption requirements for proceeds from an Italian real estate investment fund—specifically when the unit-holders are foreign partnerships that indirectly own the real estate investment fund units through fully owned vehicles.

1000

Related content

In general, “closed-end” real estate investment funds established in Italy and managed by an authorized management company are exempt from Italian corporate income tax, provided that:

  • The fund makes collective investments for a plurality of unit-holders or for a single unit-holder (e.g., a pension fund or investment fund representing a plurality of interests).
  • The authorized management company manages the fund on behalf of and for the benefit of the fund’s unit-holders (but autonomously and independently of them).

Proceeds that a foreign unit-holder receives from an Italian real estate investment fund may be subject to a final withholding tax at the standard rate of 26%. However, an exemption from withholding tax may apply for proceeds distributed to certain foreign resident investors.

The statements of practice provide a description of the requirements that foreign investors must satisfy in order to benefit from the tax exemptions for proceeds from the Italian real estate investment fund units that they hold.

 

Read an October 2018 report [PDF 167 KB] prepared by the KPMG member firm in Italy

© 2019 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.

Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm.

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us

 

Want to do business with KPMG?

 

loading image Request for proposal