The webinar organized by the SUPSI Tax & Legal Competence Centre will analyze recent developments in administrative practice and case law concerning tax and inheritance law aspects of the trust in Italian-Swiss relations. It will begin by focusing on three decisions of the Tax Chamber of the Court of Appeal of the Canton of Ticino concerning trusts and Liechtenstein Anstalten (nos. 80.2023.72, 80.2019.319/320 and 80.2022.36/37), dealing with cases of interposition, tax transparency and tax avoidance, highlighting the importance of a substantive analysis of the settlor’s powers and the beneficiaries’ rights for income, wealth and inheritance tax purposes.
Remaining on the Swiss side and in the field of inheritance law, the webinar will then present the scope of the Swiss Federal Supreme Court decision (DTF 151 III 361), which clarified that the assets of an irrevocable and discretionary trust do not form part of the estate and that the mere designation of beneficiaries does not constitute a gift subject to collation, thereby strengthening legal certainty in estate planning in Switzerland.
On the Italian side, two very recent rulings issued by the Italian Revenue Agency will be discussed. The first (no. 239/2025) addresses the case of a U.S. trust initially treated as interposed (Grantor Trust) that became irrevocable upon the settlor’s death; in the presence of beneficiaries resident in Italy, the Agency excludes interposition but qualifies the trust as “transparent”, considering the beneficiaries as “identified” due to their right to the residual fund, with consequent pro rata attribution of income, while the capital remains subject to inheritance tax only at the time of final distribution. The second ruling (no. 17/2026) concerns capital gains on Italian shareholdings held through a Swiss trust: in this case, the Agency qualified the trust as interposed, denying the application of the Italy–Switzerland Double Taxation Convention, with the result that taxation is due exclusively in Italy.

Programme and speakers
Recent decisions of the Tax Chamber of the Court of Appeal of the Canton of Ticino concerning trusts and Liechtenstein Anstalten (nos. 80.2023.72, 80.2019.319/320 and 80.2022.36/37)
Simona Genini
Attorney-at-law, LL.M in International Tax Law, Founder of SIGE Consulenze, Lugano

Recent case law of the Swiss Federal Supreme Court on trusts for inheritance purposes (DTF 151 III 361)
Flavio Amadò
Attorney-at-law and Notary, LL.M, Partner at COLLEGAL Law and Notarial Firm, Lugano

Advance tax ruling no. 239/2025 of the Italian Revenue Agency
Antonio Della Carità
Attorney before the Supreme Court, Partner at BDC Associati, Milan

Advance tax ruling no. 17/2026 of the Italian Revenue Agency
Marco Calcagno
Certified Public Accountant and Trustee (TEP), GISEV Family Office, Lugano

Fee
CHF 350.–
CHF 50 discount for members of partner institutions

Registration
https://bit.ly/webinar-03-09-2026

Registration deadline
Tuesday, 1 September 2026