Bersani Law Firm & Partners · Private Client

One lawyer, accountable for the Italian side of everything

For families and their advisers where the Italian question is not a single transaction: an asset, a residence, a tax position, a succession and — often — a citizenship that the family did not know it held.

Most of what is written in English about these subjects is out of date, and some of it is wrong in ways that cost money. We work from the statutes, we date what we publish, and we say when a position is contested rather than selling certainty that does not exist.

From €2 million

We act on private client mandates from around that figure. Below it, our standard service is the better and cheaper answer, and we will say so.

  • You deal with the admitted lawyer, not an account manager
  • Local specialists selected for the asset and the place, instructed and supervised by us
  • No commission from any agent, seller or intermediary — ever
  • A limited number of these files at a time
Who we act for

Usually the family. Often through the people who already advise them.

The enquiries that reach this practice rarely come from the principal first. They come from a family office asked to find Italian counsel, from a US estate attorney who needs the Italian limb of a plan to hold, from a private banker whose client has signed something in Tuscany, or from a tax adviser who has found an Italian asset in a structure and wants to know what it does.

We are comfortable inside that arrangement and we do not try to displace it. We take the Italian part, we report to whoever the family has designated, and we do not offer opinions on the parts that belong to somebody else. When our view of the Italian position affects the wider plan — and on succession it usually does — we say so to the adviser rather than around them.

What we ask in return is to be brought in before the commitment rather than after it. Almost every expensive problem we are asked to fix was cheap to prevent: a purchase proposal signed at a viewing, a will that chooses “United States law”, a residence transferred in the wrong order, a painting shipped without a certificate.

How we work

We build the team around the asset, not the other way round

Italy is not one jurisdiction in practice. The building office in a Tuscan hill town, the soprintendenza that governs a lakeside villa and the land registry for a Piedmontese estate behave differently, and the professional who is excellent in one is unknown in the next.

Selected for the place

We appoint the surveyor, the technician, the agronomist or the local counsel the particular asset and location require, having looked at what the file actually needs rather than at who is on a list.

Instructed and supervised by us

They are briefed by us, they report to us, and we read their work before you see it. You do not manage a panel of Italian professionals, and you do not receive five separate reports to reconcile.

One point of accountability

Whatever the file needs and whoever carries it out, one admitted lawyer stays answerable for it. That is the whole of the proposition, and it is the part that cannot be delegated.

The mandates

Six things we are asked to do, and what each one turns on

They are listed in the order a family usually meets them, not in order of importance. In practice the last two are where the value is, and they are the two that arrive last.

1
Acquisition

The asset

A house at this level is rarely one thing. It is a title, a set of cadastral parcels, a building history that may or may not match the permits, and — often — a constraint registered against it by the State.

Three of those go wrong quietly. Urbanistic conformity, because no one in the transaction is legally obliged to check whether the house as built matches the permits it was built under: the seller declares, the notary records the declaration. Cadastral conformity, because an estate is dozens of parcels across several sheets and a single non-conforming plan renders the deed void. And the State’s right of pre-emption over a property declared of cultural interest, which is neither theoretical nor rare.

We do the work that answers those three questions before you are bound, and we say plainly when the answer is that you should walk away.

The transfer of a declared cultural property must be notified to the Ministry within 30 days. The State then has 60 days from the notification to pre-empt, at the price stated in the deed. Where the notification was omitted, late or incomplete the period is 180 days — and a notification missing its required elements is treated in law as never made. Agreements between buyer and seller do not bind the State.
2
The right to be here

Residence

Most families arrive at the property question and discover a residence question underneath it. The first-home tax rate requires residence in the municipality within eighteen months, and registering residence as a non-EU national requires a permit that a ninety-day visitor does not hold. The difference between the two rates on a substantial purchase is not a rounding error.

There are two routes that work for this client, and they suit different people. The investor visa does not require you to live in Italy at all for as long as you hold it, and the money moves only after the visa is granted. The elective residence visa is built for passive income and is refused when the income is earned. Choosing wrongly costs a year.

We advise on the route, prepare the file, and deal with the consulate that has jurisdiction over the client’s state of residence — each of the ten applies the same rules in a slightly different way, and we publish what each one requires.
3
Before the move, not after

Tax on arrival

Italy’s substitute tax for new residents is €300,000 a year on all foreign income, whatever its size, plus €50,000 for each family member included, for anyone transferring tax residence from 1 January 2026. It runs up to fifteen years and requires that the person was not resident in Italy for nine of the ten preceding years.

Whether it is worth electing is arithmetic, and the arithmetic has to be done before the move rather than in the first return. So does the sequencing: the order in which a family transfers residence, funds a structure and acquires an asset changes the outcome, and some of those steps cannot be undone.

Read the detail on the flat tax for new residents, including the 7% regime available to holders of a foreign pension who settle in the South, and the rule from tax period 2027 that closes the combination with the inbound-worker regime.
4
What happens to the Italian assets

Succession

This is the mandate that American advisers most often bring us, and the one where the English-language material is least reliable.

The European succession regulation applies the law of the deceased’s habitual residence to the succession as a whole. A person may instead choose the law of the State of their nationality — and the Regulation says a State, not a Member State, so a US citizen can make that choice.

But “United States law” is not a thing that exists for this purpose. Where the chosen State has several territorial units with their own succession rules, the Regulation routes to the unit with which the deceased was most closely connected. A will that chooses “the law of the United States” has chosen nothing identifiable. It needs to name a state, and the choice needs to survive a challenge on the facts.

And the honest answer on forced heirship. Italian law reserves fixed shares to the spouse and children. The prevailing Italian view — supported by consistent case law predating the Regulation, and by notarial doctrine — is that those reserved shares are not part of Italian international public policy, and that a validly made choice of a US state’s law therefore displaces them. We think that view is right. We will not tell you it is guaranteed: no Italian court has yet ruled on the point under the Regulation, the domestic safeguard that used to protect Italian-resident forced heirs was displaced without replacement, and a disappointed child can still bring the argument. What we can do is set out precisely how strong the position is and where the residual risk sits, which is what a risk memo needs.

Italian inheritance tax is low by European standards and is charged per beneficiary: 4% to the spouse and direct line above €1,000,000 each, 6% to siblings above €100,000, 6% to other relatives within the fourth degree with no threshold, 8% to everyone else. Where the deceased was not resident in Italy, only Italian assets are taxed. Since 1 January 2025 the tax is self-assessed. For a family arriving with an existing US trust, the 2024 reform taxes the transfer to the beneficiaries, with an election to pay up front instead — a decision that is made once and cannot be reversed.
5
The asset nobody counts

Citizenship

A large part of this clientele is of Italian descent and does not know that the family may already hold a status it never lost. Citizenship by descent is not a sentimental exercise and it is not an investment programme: it is a status that, where it exists, has existed all along.

For a family considering Italy it changes the terms of every other question on this page — the right to be here without a permit, the first-home rate, freedom of establishment for the children, and a European passport for a line of descendants rather than for one applicant. It is also, by a wide margin, the cheapest of the routes into Italy, because there is nothing to invest.

It is now largely a matter for the courts. We litigate these cases, and we publish the decisions — including the ones we lost.

Where the line is established, the status extends to the descendants who qualify, not only to the person who applies. That is the difference between a residence permit, which is personal and conditional, and a citizenship, which is neither.
6
Art and cultural goods

Collections

Families who buy a house in Italy furnish it, lend from it, inherit into it and eventually move things out of it. Almost everything written in English about that is out of date.

Moving a work of art out of Italy requires a certificate of free circulation where the work is over seventy years old by an author no longer living and above a value threshold. That threshold changed in April 2026, from €13,500 to €50,000 — a change we have not seen reported in English anywhere. Below it, a self-declaration regime applies instead.

Two traps matter more than the paperwork. A work that has been declared of cultural interest cannot be permanently exported at all, only temporarily. And the State’s right of pre-emption applies to movable declared goods exactly as it does to buildings — same notification duty, same sixty days, same one hundred and eighty if the notification was defective.

The penalty for getting this wrong is also misreported in English: the provision most sources still cite was repealed in 2022, and unlawful export is now a criminal offence carrying two to eight years.

Practical clocks that do not line up: the Italian certificate is valid five years and is not renewable; the EU export licence needed for a shipment to the United States is valid twelve months. The export office decides within 40 days. Works entering Italy can be documented on arrival so that they can leave again.
Questions

What advisers ask before they introduce a client

Do you act for the family, or for the adviser who introduced them?

For the family, and that has to be said clearly, because it is what makes the advice worth having. But we are used to working inside an existing structure — a family office, a US estate attorney, a private bank, a tax adviser already in place — and we do not attempt to displace it. We take the Italian part, report into whoever the family has asked us to report to, and stay in our lane on the rest.

You mention local professionals. Do you have them on staff?

No, and we would be suspicious of any Italian firm that claimed to. The surveyor who knows the building office in Cortona is not the one who knows the building office on Lake Como, and an agronomist who understands a Barolo estate is the wrong person for an olive property in Puglia. We select and instruct the specialists the particular asset and location require, we brief them, we read their work, and we remain answerable for it. What the client gets is one lawyer accountable for the whole file, not a directory of contacts.

Is there a minimum?

We act on transactions and mandates from around €2 million. Below that our standard property service is the better and cheaper answer, and we will say so rather than take the file.

How do you handle confidentiality?

Italian professional secrecy binds us as a matter of law, not of policy. Beyond that: we do not publish client names, we do not use transactions as case studies, and we do not issue press comment on matters we have acted in. Where an acquisition needs to stay out of public view for a period, that is a structuring question we can address at the outset — but no one can promise that a deed, which is a public act, will be invisible.

Who will actually do the work?

Marco Bersani, admitted at the Bar of Verona and as an abogado ejerciente at the Bar of Madrid. On a private client mandate you deal with him directly and not with an account manager. This is also why the practice takes a limited number of these files at a time, and will tell you when it cannot take another.

What if we also have Spanish interests?

Then say so early. Spain closed its golden visa with effect from April 2025 and a number of families are reconsidering positions built around it. Being admitted in both countries means we can answer the comparative question rather than referring it out, which in practice is where the sequencing decisions get made.

Marco Bersani, Avvocato (Bar of Verona), Abogado ejerciente (Bar of Madrid), founding partner of Bersani Law Firm & Partners, Verona. Positions on this page are taken from the sources, read on 11 September 2026: Regulation (EU) 650/2012, articles 21, 22, 35 and 36; articles 536 to 542 of the Italian civil code; Legislative Decree 346/1990 as amended by Legislative Decree 139/2024 on inheritance and gift tax; article 24-bis of the income tax code as amended by Law 199/2025; Legislative Decree 42/2004 on cultural heritage, articles 59 to 62, 65, 66 and 68, as amended by Law 40/2026; article 518-undecies of the criminal code; Regulation (EC) 116/2009 and Regulation (EU) 2019/880. Where a position is contested we have said so rather than resolved it in our own favour.

This page is general information and not legal advice. Nothing here creates a lawyer-client relationship, and no two families arrive with the same facts.
Enquire

Tell us what is being decided, and by when

A paragraph is enough to start: what the asset is, where the family is resident, what has already been signed, and who else is advising. We will tell you whether this is a mandate for us, and if it is not, we will say who it is for.

  • Answered by the lawyer
  • Covered by professional secrecy
  • No obligation, no fee for the first exchange

If the question is narrower — a single purchase, a visa, a citizenship line — the service pages cover it: property, investor visa, elective residence, flat tax.

Please, write it correctly – or it will be impossible to reply to you back.
As much or as little as you are comfortable putting in writing. This message is read by a lawyer and is covered by Italian professional secrecy from the moment it arrives.
A deed, a closing, a filing deadline, a move, a hearing.

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