Italy Tax Agency Clarifies Taxation of Investments Under Managed Savings Regime After Tax Residence Change

The Italian Revenue Agency Aug. 14 issued Letter No. 208/2025, clarifying the taxation of investments under the managed savings regime following a change in tax residence. The taxpayer, an Italian citizen, moved their tax residence to Thailand, obtained a 10-year visa, and enrolled in the Registry of Italians Resident Abroad (AIRE). The taxpayer held a securities account with an Italian intermediary under the managed savings regime and sought clarifications regarding whether transitioning to the declaratory regime was mandatory, and whether latent capital gains on securities held at the time of a regime change or tax status would be taxed. Upon ...