Italy Tax Agency Clarifies Gift Tax Exemption on Bare Ownership Transfers of Partnership Interests

The Italian Revenue Agency June 4 issued Letter No. 116/2026, clarifying the gift tax exemption on bare ownership transfers of partnership interests within a family business succession. The taxpayer, an individual controlling shareholder, sought clarification on whether the generational transfer exemption applied for transferring only the bare ownership of partnership interests to heirs, while retaining limited rights. Upon review, the Revenue Agency clarified that: 1) the exemption aims to ensure an effective generational transfer involving real transfer of management and control; 2) although bare ownership transfers may qualify in principle, the beneficiary must acquire full substantive rights enabling active participation ...