What changes when a client moves to Italy depends almost entirely on where they are coming from. These are the technical guides by departure jurisdiction, written for the adviser rather than the client.
The mandate question comes first. Since MiFID passporting ended, a UK-only authorised firm faces a real question about whether it can continue to act, and reverse solicitation is read narrowly in Italy. Alongside it: UK OEICs and unit trusts are frequently non-harmonised for Italian purposes, the ISA wrapper is disregarded, and temporary non-residence rules bite if the client returns within five years.
Usually workable, but the details bite. Swiss institutions generally serve Italian residents under defined cross-border frameworks, so the relationship typically survives. The technical work is elsewhere: pillar 2 and pillar 3a sequencing, recovery of the 35% Swiss withholding through the treaty, and the comparison between the Swiss forfait and the Italian flat tax. Switzerland is no longer on Italy's privileged-taxation list.
The client never stops being a US taxpayer. Citizenship-based taxation means the client acquires a second system rather than swapping one for another. Many US custodians restrict or close foreign-resident accounts. European funds are PFICs and attract punitive US treatment. The Roth exemption does not necessarily travel to Italy. Optimising for one jurisdiction often damages the other.
Documentation, not regulation. There is no passporting problem. The binding constraint is source of funds: Italian banks require a documented economic history spanning years, and assembling it takes months. Free zone structures attract CFC attribution. Unrealised gains should usually be crystallised before Italian residence begins.
A simpler position: freedom of movement applies, passporting is unaffected, and the technical work concentrates on the tax regime election and pension coordination. EU pension coordination.
Client Feasibility Report — a written analysis of a specific case: applicable regime, treatment of existing holdings and structures, costs, timeline, and the points at which decisions become irreversible.
Relocation Execution — coordination on the ground once the client decides: accountant, property, schools, healthcare, banking, permits.
Technical Desk — an annual retainer giving your team unlimited technical questions on Italy for any client, plus a quarterly briefing.
Contact: info@theitaliangateway.com