Succession: New tax regulations introduced starting in 2025

With the entry into force of Legislative Decree No. 139/2024, implementing the tax reform, the rules governing inheritance and gift tax have significantly changed. These changes aim to simplify compliance for taxpayers by introducing a more modern and efficient system.

One of the main changes is the introduction of the self-assessment system: starting January 1, 2025, the Revenue Agency will no longer calculate the tax and request payment via a payment notice. However, those required to file the inheritance tax return are responsible for calculating and paying the tax independently.

The inheritance tax payment must be made within 90 days of the deadline for filing the return, which remains set at 12 months from the date of opening of the inheritance. In practice, taxpayers will have 15 months from the date of opening of the inheritance to correctly pay the tax.

To guide taxpayers through this new phase, the Revenue Agency has published Circular 3/E/2025, which provides detailed operating instructions to ensure uniform application of the new rules. The document also provides a summary of the regulatory changes introduced, valid for inheritances and donations opened starting in 2025.

Among the points addressed in the circular, the methods for determining inheritance tax are explained, along with a summary of the rates applicable to the overall net value of the assets and rights transferred.

The circular recalls the new provisions introduced regarding tax penalties, implementing the provisions of Legislative Decree No. 87/2024, which affects tax violations, including those relating to inheritance.