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San Marino: Resident trust disregard for income tax and foreign asset reporting purposes

Ruling Answer No. 125/2026 published on June 18, 2026

July 29, 2026

The Italian Revenue Agency on June 18, 2026, published Ruling Answer No. 125/2026, clarifying that a resident trust governed by San Marino law is disregarded for income tax and foreign asset reporting purposes.

The ruling addresses the fiscal qualification of the trust, foreign asset reporting obligations, and wealth tax (Imposta sul Valore delle Attività Finanziarie detenute all’Estero, or IVAFE) liabilities for financial assets formally held by the trustees.


For more information, contact a KPMG tax professional in Italy:

Alessandra Tronconi | atronconi@kpmg.it

Lorenzo Schippa | lschippa@kpmg.it

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