Estate Planning in Italy (UK Nationals)
Italy attracts a particular kind of British retiree — often someone drawn south by the 7% flat-tax regime for new residents in qualifying southern municipalities, or by the broader lifestyle pull of Tuscany, Umbria and the lakes. The Italian tax position is unusually generous. The UK estate position behind it is unchanged, and almost always under-planned.
The Italian rate is gentle. The UK rate is not.
Italy charges 4% inheritance tax between spouses and direct descendants, on values above a generous threshold. The UK charges 40% on UK-domiciled estates above £325,000. Most British clients in Italy remain UK-domiciled for years after moving.
Italian succession tax (imposta di successione) is 4% between spouses and children with a €1m per beneficiary exemption, 6% between siblings with a €100,000 exemption, and 8% to others with no exemption. By international standards this is mild. It is also the figure most clients quote when explaining why they don't think they need a plan.
UK Inheritance Tax follows UK domicile. The decision to live in Italy under the 7% flat tax, the standard tax-residency regime, or the impatriate worker regime does not, on its own, end UK-domiciled status. Deemed-domicile rules and the new long-term residence rules from April 2025 keep most British clients inside the UK IHT net for several full tax years after departure, and often longer.
From April 2027 unused UK pensions enter the UK IHT estate. The 7% flat-tax regime in Italy applies to foreign income including pension drawdown for ten years from election. The two clocks — Italian income tax favourability and UK IHT exposure — do not run on the same timeline, and the planning has to account for both.
The 7% flat-tax regime for new residents
Available to retirees moving to qualifying municipalities in southern Italy with under 20,000 inhabitants. Foreign-source income is taxed at a flat 7% for up to ten years. The regime is real and worth using. It does not, however, change the UK IHT analysis on the underlying assets — and the right time to plan is during the ten-year window, not after it ends.
Italian forced heirship and the English-law election
Italy applies forced-heirship rules (legittima) reserving fixed shares for spouses and descendants. Brussels IV permits an English-law election to govern succession of Italian assets, and Italy continues to recognise this in practice. Without the election, default Italian law applies — which can disinherit a second spouse or distribute the estate in ways the client did not intend.
Property held jointly with a non-British spouse
We see this often. The client is British-domiciled; the spouse is Italian or another EU national. The Italian villa was bought jointly. The English will leaves everything to the spouse. On death, the UK IHT exposure runs on the British client's share; Italian succession tax on the spouse's inheritance is mild but the UK side is untouched. The planning is to coordinate the two so neither system creates a surprise.
Where we typically come in
English Wills with Brussels IV election
Drafted to elect English law for the succession of your Italian property and coordinated with your Italian notaio.
Read more →UK Inheritance Tax Planning
Built around the April 2027 pension change, the new long-term residence rules, and any retained UK property or business interest.
Read more →Lasting Power of Attorney
An English LPA for your UK assets and decisions. Italy has its own framework (amministrazione di sostegno) which is court-driven and slower — the LPA is the document that avoids it on the UK side.
Read more →Property Trusts (UK)
For any UK property retained on let or for family use, a Property Trust on the UK will protects against UK care-fee exposure and unintended onward transfer.
Read more →What we'd actually do for you
A first call is free, by video. We read your existing English will, any Italian will, the property paperwork and the pension position, and tell you what is currently in force on each side. From there we draft the English-side documents, coordinate with your Italian notaio on the local side, and build the IHT plan to match the timeline of your Italian residency status — particularly if you are inside the 7% flat-tax window.
Complete the Discovery first - then we'll book your free 30-minute consultation.
Common questions from clients in Italy
I'm on the 7% regime. Does that affect my UK Inheritance Tax position?
No. The 7% regime is an Italian income-tax election; it has no effect on UK IHT, which follows UK domicile. The regime is genuinely valuable for income tax. The estate-planning question runs in parallel and needs to be handled separately.
Do I need an Italian will if I have an English one?
For Italian-located assets — particularly real property — an Italian will drafted to coexist with your English one is usually the cleanest route. The two need to be drafted together so neither revokes the other. Done well, each governs the assets in its own jurisdiction.
Italian inheritance tax is only 4% — why plan for the UK side?
Because the UK rate on the same assets, for a UK-domiciled person, is 40%. The Italian figure is real for the Italian side. The UK side is unaffected by it and, for most clients, is the larger of the two by a wide margin.
Do I need to come to your office to work with you?
No. We work nationally — and increasingly internationally. Most of our clients in Italy are seen by video call, with documents signed remotely or couriered when wet signatures are needed. The advice is the same. The convenience is yours.
Is Sean Kiani regulated?
Sean Kiani is a member of the Society of Will Writers and holds full Professional Indemnity Insurance. Estate planning is unregulated in the UK — which is precisely why credentials, supervision and indemnity matter.
What does a first conversation cost?
Nothing. A first call is free, confidential, and exists for one purpose: to find out whether your current arrangements still do what you think they do. If they do, we'll tell you. If they don't, you'll know exactly what's exposed and what to do about it.
Your 30 minutes. Simple. Yours.
No-obligation.
The path is simple: complete the Discovery first so we walk into the call already knowing the facts. Then in 30 focused minutes, I listen, answer your questions, and you choose if you'd like us to draw up your Inheritance Plan.
1. Start Your Discovery
Required first step. Complete the confidential financial position review so your no-obligation 30-minute consultation starts with the facts, not the basics.
2. Request a Callback
Prefer to speak first? Leave your details and we'll call you back to talk through the Discovery before you complete it.
You choose the date, time, and format - phone or online. Bring anyone you'd like.