For a house you and your family will use, personal ownership is usually right. For property bought to produce income — several units, a commercial building, something to be developed or let as a business — a company starts to earn its cost. What moves a case off that default is below, whether you buy from New York, London, Dublin, Toronto or Sydney.
Buying personally
Cheaper to set up, and it keeps three things open. Prezzo-valore: on request in the deed, an individual buying a home outside a business has transfer tax computed on the cadastral value rather than the price, normally the lower figure. Main-residence relief, if you genuinely take up residence. And the flat substitute tax on rental income, at a rate depending on how many properties you let short-term.
A gain on a sale more than five years after purchase generally escapes capital gains tax, though building land and recently renovated buildings follow different rules. The cost is exposure: the asset sits in your estate.
Buying through an Italian company
Liability separation, costs deducted against income, partners who can come in, an exit by share transfer rather than a notarial sale. Against that: Italian bookkeeping, annual filings, corporate tax, beneficial-ownership reporting whose scope keeps shifting, and a company that must genuinely exist. Prezzo-valore is closed to companies, and VAT may apply instead of registration tax depending on who sells.
Italy's regime for non-operating companies — società di comodo — also targets entities holding assets without proportionate revenue: a company owning a house nobody lets is that profile, with consequences from deemed minimum income to restricted VAT credits.
If the company is at home rather than in Italy
A US LLC or corporation, a UK or Irish company, a Canadian or Australian structure can all hold Italian real estate, each with its own Italian tax code, filings and IMU. The awkwardness is rarely Italy but the interaction: Italy may treat a US LLC as opaque while the US treats it as disregarded, and treaty relief and credits do not always survive it.
The sharper problem is personal use: in almost all these systems, letting a shareholder occupy corporate property for nothing is taxable — shareholder-benefit rules in Canada, Division 7A in Australia, benefit-in-kind and close-company treatment in the UK and Ireland, constructive dividends in the US. With Italy's non-operating regime on top, a holiday home in a company is taxed twice over.
Death, and the choice most wills never make
Italian succession law reserves fixed shares for close family — spouse, children, and failing children the ascendants — enforceable by an action to reduce dispositions that encroach on them. The fractions depend on family composition, they bite on Italian real estate, and a will drafted at home may not do what you assume.
But that is not fixed, and this is the part usually left out. Succession in Italy is governed by EU Regulation 650/2012: by default the law of the deceased's habitual residence at death, but a person may instead choose the law of a State whose nationality they hold, at the choice or at death, to govern the succession as a whole — EU country or not. So an American, British, Irish, Canadian or Australian national can designate their own, within limits that matter as much as the right:
- It is made in the will, expressly or clearly from its terms — not something heirs can elect afterwards.
- Name the unit, not the country. "The law of the United States" leaves the routing to be argued after death; New York, Ontario, Victoria or Scotland does not. Scots law, unlike England and Wales, has protected shares of its own.
- Doing nothing is not neutral. Absent a choice, renvoi can send the question back to Italian law for the Italian house, since several common-law systems refer immovables to where they sit. A choice switches renvoi off.
- Ireland and Denmark are not bound, and the UK never opted in — which does not stop an Irish or British national choosing their national law: the Italian authority applies the Regulation. How your own system treats the Italian estate is a separate question, for a solicitor in Dublin or London or counsel in Canada, Australia or the US.
- It does not touch tax, and one point is contested. Italian inheritance tax applies to Italian assets whatever law governs. And whether an Italian court could refuse a chosen law that leaves a child with nothing, on public-policy grounds, is debated — the prevailing view is that the reserved shares are not in themselves a barrier, but it is unsettled.
A company reshapes this — you leave shares, not land — without removing it; see our guide to cross-border succession. The cheapest moment to decide is at purchase.
Two checks before you commit either way
Where the seller's title came from. If the seller was given the property, reserved-share claims of the donor's family can in defined conditions reach it in a later buyer's hands, within limits set by the Civil Code and softened by a 2005 reform — which is why Italian banks often decline to lend against such a title. Ask for the chain of title early, with the rest of the due diligence.
The number nothing works without. Every buyer, and every foreign entity, needs an Italian codice fiscale before the deed — in practice before the preliminary contract. And the deed itself is not a closing in the common-law sense.
What your own tax authority will expect
- United States. Foreign real estate held directly is not itself an FBAR or Form 8938 item; the Italian account you open to run it is, once your accounts pass the threshold. A foreign entity brings Form 5471 or 8865.
- Canada. Specified foreign property above the CRA cost threshold goes on T1135 — personal use excluded, a rental not; a foreign affiliate brings T1134. No estate tax, but a deemed disposition at death.
- United Kingdom. Foreign income and gains go on the self-assessment foreign pages; April 2025 replaced the remittance basis with a residence-based regime and moved inheritance tax to a long-term residence test, so older advice needs checking with your solicitor.
- Ireland. Residents are self-assessed on worldwide income, Italian tax relieved under the treaty; capital acquisitions tax and the close-company surcharge on undistributed investment income are for your solicitor.
- Australia. Residents are taxed on worldwide income with an offset for Italian tax; no inheritance tax, but death carries capital gains consequences the structure affects.
Italy has a treaty with each, but any credit depends on its terms.
How we work through it
We set the options side by side: setup and annual cost, tax on purchase, income and exit, IMU and short-let licensing, what a bank will lend, reporting at home, succession.
Send us the listing, the proposal or the draft preliminary contract and we will say what we would check. That first conversation costs nothing and commits you to nothing — and how it lands depends on your family, your residence and the building itself, which is why it is decided case by case.