Often Italian citizens leave the country once they are pensioned off, moving elsewhere to enjoy the remaining days of their lives in sunny hotspots with a more affordable cost of living. The question is whether the earnings of those private equity funds may have to be taxed in Italy or the country of the citizen’s residence.
Let’s start by saying that individual circumstances will require a specific interpretation. So there seldom is a simple answer, and we can only generically address this matter.
The first assumption is that a person is regularly registered with AIRE and then moved to a country with reciprocal fiscal arrangements. In those specific instances, earnings that have matured from Italian pension funds should not be taxed where they were generated (Italy) but would instead need to be declared and therefore paid in the country of the citizen’s residence. Any paid taxation at source should be appealed against and eventually reimbursed, as it would otherwise generate double taxation.