It means that if you own over 2/5% of a listed company or 20/25% of a private company (depending if your ownership has or not voting rights), you cannot include the sale of those stocks in the flat tax in the first 5 years.
Excellent clarification, thanks @JohnnyDoe
Why should you do so? You can keep the company as the dividends are covered by the flat tax.
I was thinking along the lines of closing the company as you suggested before. Given that the flat tax doesn't cover capital gains from funds moved after dissolving a foreign company until the 6th year, this might be an alternative solution to distancing & closing quickly, yet continuing to live in Italy.
“Giving away” the company will not withstand a tax investigation.
Makes perfect sense.
There is no exit tax for individuals. Chances are that a person taking advantage of the €100k flat tax who moves his residence outside Italy will be left alone by the Italian authorities. Of course as long as the expatriation is real and no assets are left in Italy.
What about an owned foreign company which under CFC rules was also technically an Italian tax resident in 2021?
If it's resident in Italy you are supposed to have an Italian accountant taking care of it. If you don't have one you should better find it quickly and fix your position.
