Italian Tax Authority Circular no. 16/E/2023. Clarification on the franking of higher values of units and shares of CIUs.

26 June 2023

The Italian Tax Authority has just published Circular No. 16/E with the long-awaited clarifications on the discipline of franking the higher values of units and shares of UCITS and life insurance contracts.

The Circular provides important confirmations, in line with early comments made on the framework under review by major trade associations and early commentators.

Among the most important clarifications provided, the Tax Administration confirmed the hoped-for possibility of franking even units or shares of UCIs with enhanced property rights (so-called “𝘤𝘢𝘳𝘳𝘪𝘦𝘥 𝘪𝘯𝘵𝘦𝘳𝘦𝘴𝘵”), provided that the related income qualifies as income of a financial nature.