Question Refusal of 70-90% Income Exclusive in Italy, What Netx?

[A1988]

Just wanted to bring to everyones notice that my request has been refused for 70-90% exemption in Italy stating "I did not move to italy with the intention to take the 70-90% exemption of income". I was involved in Research and Development activity and finished the R&D in 2023 and moved to italy in 2019. Again, I did not make any income in this period in Italy and now when the time came for commercialization of the product I am stuck with this huge blow. I have my R & D in Italy and a business partner based in Italy, hence I moved.
My present situation is that,

1. I would like to move out of italy without creating any problems or trigerring any issue with the tax authorities.
2.I would like to move to either UK, Ireland, Malta (less preferred0 and take advantage of non dom program also I have 2 kids who would start their preschooling.
3. I would like to know if anyone knows if a structure where I pay 0-5% in corporate tax?
4. I have my business partner and R and D in Italy so daily flights would be a plus, ideally within 2hrs and not more.
5. I am expecting capital gains in the next 3-4 years.

Any suggestion or experience of the situation would be very welcome, I would want to stay in the country permanently and want my children to build their life and network in it, I am not really interested in Middle eastern countries as I have lived there and I feel its not best for my children to be exposed to that lifestyle and specially having daughters. I turn 35 in may this year.

sorry for excessive information, just wanted everyone to know that the regime can come up with any kind of excuses to refuse of accept what suits them or their objectives.

 

[JohnnyDoe]

I would want to stay in the country permanently and want my children to build their life and network in it

This is the definition of what non-domicile is not.

I would not recommend anyone to have their children build their lives in Europe.

 

[A1988]

This is the definition of what non-domicile is not.

I would not recommend anyone to have their children build their lives in Europe.

why would you not recommend children to build their lives in europe

 

[JohnnyDoe]

why would you not recommend children to build their lives in europe

Can you see what is happening to Europe? Or are you suffering from the boiling frog syndrome?

 

[RealDude]

Can you see what is happening to Europe? Or are you suffering from the boiling frog syndrome?

Enlighten us.

 

[Konstanz]

I don't think there is a country you are searching for
Just pay tax

 

[void]

having emotional home, family/personal ties and business connections and history in Europe is a sad situation and I'm struggling with this myself
however voluntarily move into European country and thinking about building future for your kids there is a pure insanity

 

[JohnnyDoe]

Enlighten us.

No worries, enjoy Ursulandia

 

[A1988]

Can you see what is happening to Europe? Or are you suffering from the boiling frog syndrome?

boiling frog syndrome from a tax perspective, hell yes. But, still you wont find better quality of life, infrastructure, equal laws , less corrupt politicians, way less poverty in most parts of europe than anywhere else in the world. I am sure there are places where you can pay less taxes aand maybe have a bigger market for your product and a less lazy and entitled population, but overall still Europe is still balanced as compared to other parts of the world.

I have concluded that places like Dubai/monaco are way more dangerous to build a future than europe will ever be. All the consultants I speak only talk about Dubai without taking into account how dangerous it is geo-politically and close to saudi arabia and yemen.

 

[Konstanz]

I have concluded that places like Dubai/monaco are way more dangerous to build a future than europe will ever be. All the consultants I speak only talk about Dubai without taking into account how dangerous it is geo-politically and close to saudi arabia and yemen.

How Monaco is dangerous?

 

[A1988]

How Monaco is dangerous?

I mean dangerous for children here, from a geopolitical standpoint its still safer than dubai. Although, people are still worried about russia.

 

[JohnnyDoe]

But, still you wont find better quality of life,

That's subjective

infrastructure,

There are third-fourth world countries way ahead of certain zones of Europe, including Italy

equal laws ,

in which movie?

less corrupt politicians,

way less poverty

wait a few years...

 

[bisk]

I have concluded that places like Dubai/monaco are way more dangerous to build a future than europe will ever be. All the consultants I speak only talk about Dubai without taking into account how dangerous it is geo-politically and close to saudi arabia and yemen.

Close to Saudi Arabia... which is their biggest ally? Close to Yemen which is constantly weakened by this alliance? Geopolitically you know nothing.

my request has been refused for 70-90% exemption in Italy stating "I did not move to italy with the intention to take the 70-90% exemption of income".

Message is pretty clear, you messed up the paperwork.

1. I would like to move out of italy without creating any problems or trigerring any issue with the tax authorities.
2.I would like to move to either UK, Ireland, Malta (less preferred0 and take advantage of non dom program also I have 2 kids who would start their preschooling.
3. I would like to know if anyone knows if a structure where I pay 0-5% in corporate tax?
4. I have my business partner and R and D in Italy so daily flights would be a plus, ideally within 2hrs and not more.
5. I am expecting capital gains in the next 3-4 years.

If you're sure your profits will be substantial, move to Malta, incorporate company abroad which have special tax for IP (Cyprus probably). Your kids will learn English in 3 years then move on to some other country.

 

[Houdini]

If you're sure your profits will be substantial, move to Malta, incorporate company abroad which have special tax for IP (Cyprus probably). Your kids will learn English in 3 years then move on to some other country.

Could work well, I still don't get the the great opposition to Europe and the EU. Apparently there is no explanation either.

 

[oldtimer2]

Unfortunately these days we need far more exact info about your circumstances to be able to give anything like specific advice. So all you can hope for it general suggestions that may or may not really match your situation. I am not sure what expert advice you have sought or bought in Italy, but trying to resolve your tax status in Italy could be way cheaper than setting up structures and safer in the long run also if you are only setting up international structures for tax minimization. As for Malta - they can ask you for your entire structure setup and beneficial owners etc etc. As others suggest, if you leave Italy and since you are in a build up phase for your business, then go live in a low tax country for a few years where you can retain most of your profit while keeping your structure as simple as possible. You might have to compromise on quality of life for a couple or few years but you can reap the cash benefits. Just be sure you get expert advice before taking any decisions and understand the implications of R&D done in Italy and partner in Italy - and what that means as you change countries now and into the future. Sorry, but these days there is no quick and easy solution but only general advice.

 

[Marzio]

If you're sure your profits will be substantial, move to Malta, incorporate company abroad which have special tax for IP (Cyprus probably). Your kids will learn English in 3 years then move on to some other country.

If you are talking about Cyprus IP box he wouldn't qualify since R&D wasn't performed in Cyprus

https://ipbox.cy/

 

[A1988]

That's subjective

There are third-fourth world countries way ahead of certain zones of Europe, including Italy

in which movie?



wait a few years...

if you want to criticise what I mentioned then please give an alternative which you think is better than what I mentioned.

Close to Saudi Arabia... which is their biggest ally? Close to Yemen which is constantly weakened by this alliance? Geopolitically you know nothing.



Message is pretty clear, you messed up the paperwork.



If you're sure your profits will be substantial, move to Malta, incorporate company abroad which have special tax for IP (Cyprus probably). Your kids will learn English in 3 years then move on to some other country.

you think being close to saudi arabia is good? being close to yemen is good? Kindly enlighten yourself with the number of houthi attacks that have been carried out in UAE and saudi arabia and you will know what I am talking. Definitely a thumbs up for the structure you recommended but definitely not your idea of geopolitics .

 

[JohnnyDoe]

if you want to criticise what I mentioned then please give an alternative which you think is better than what I mentioned.

What is good for me might not be good for you, but anything is better than the EU.

 

[A1988]

having emotional home, family/personal ties and business connections and history in Europe is a sad situation and I'm struggling with this myself
however voluntarily move into European country and thinking about building future for your kids there is a pure insanity

i dont agree with you but respect your opinion

What is good for me might not be good for you, but anything is better than the EU.

okay then tell me what is good for me if you are asking me to leave europe

Unfortunately these days we need far more exact info about your circumstances to be able to give anything like specific advice. So all you can hope for it general suggestions that may or may not really match your situation. I am not sure what expert advice you have sought or bought in Italy, but trying to resolve your tax status in Italy could be way cheaper than setting up structures and safer in the long run also if you are only setting up international structures for tax minimization. As for Malta - they can ask you for your entire structure setup and beneficial owners etc etc. As others suggest, if you leave Italy and since you are in a build up phase for your business, then go live in a low tax country for a few years where you can retain most of your profit while keeping your structure as simple as possible. You might have to compromise on quality of life for a couple or few years but you can reap the cash benefits. Just be sure you get expert advice before taking any decisions and understand the implications of R&D done in Italy and partner in Italy - and what that means as you change countries now and into the future. Sorry, but these days there is no quick and easy solution but only general advice.

thanks for taking the time to write all the details. Trust me when I say this, Italy is best if you have made your money and you are in your late 50's otherwise its hell and kills your drive and motivation to make more. I am still 34 and with 2 daughters who turn 1 in feb this year. I have made a decision that I will move out of Italy for sure, just dont know where, And yes will move my company out too.

 

[JohnnyDoe]

okay then tell me what is good for me if you are asking me to leave europe

sadly, anything is better than the EU. If you can’t decide on a country, buy a sailboat and travel the world. Your children will be forever grateful.