Family Governance in Italy: How Global Families Can Coordinate Succession, Trusts and Civil Law Rules

For internationally mobile families, moving to Italy is never just an administrative relocation. It is a shift into a completely different legal culture—one that is rooted in civil law, shaped by centuries of tradition and centred around precise rules for inheritance, family rights and the transfer of wealth. For high-net-worth individuals with cross-border assets, complex structures and multigenerational objectives, Italy can offer stability and predictability. But it also demands clarity and advance planning.

Family governance is the architecture that keeps global families aligned. It is the framework that connects wealth, relationships, succession and long-term purpose. And when a family becomes resident in Italy, this governance must be adapted to the Italian environment, harmonising foreign structures with local rules and ensuring that the family legacy remains coherent across borders.

This article explores how global families can build a robust governance model while embracing Italy as their new base.

A civil law country with a distinct approach to family and succession

Unlike common law jurisdictions where family structures can be highly flexible, Italy follows civil law principles. This means that certain rights and rules are mandatory: forced heirship, protections for spouses and children, and specific rules governing the transfer of assets. For international families accustomed to broader discretion, this can come as a surprise.

The key is not to see civil law as a limitation, but as a framework to integrate into your global strategy. Italy offers predictability: once the rules are understood, you can plan effectively. Many families choose Italy precisely because of this stability.However, it requires rethinking how wills, trusts, life insurance policies, holding companies and governance documents interact with the Italian system. This is especially important when the family holds property, business interests or financial assets across multiple jurisdictions.

A well-structured family governance plan ensures that nothing is left to chance.

Aligning family values, goals and long-term vision

Before addressing legal structures, families must address something deeper: their shared vision. Why are you moving to Italy? What do you want Italy to represent for the next generation? Stability? Education? Culture? A European base for the family business? A bridge between continents?

Family governance begins with clarity. Many families create a family charter or constitution, outlining their principles, objectives and the way decisions should be made across generations. In Italy, this soft-law instrument can be integrated with binding legal tools such as wills, patti di famiglia (family agreements), shareholder agreements and succession plans.

This clarity helps not only the founding generation but also the children and grandchildren, who will inherit a well-defined roadmap rather than a fragmented legacy.

Trusts and Italy: compatibility, transparency and purpose

For many global families, trusts are the backbone of asset protection and succession planning. Italy recognises foreign trusts established under jurisdictions that adhere to The Hague Convention, but it does so through the lens of civil law.The key questions are always the same:

Is the trust transparent or opaque?Who is the beneficial owner for tax purposes?How are distributions classified?Does the structure align with Italian succession rules?

Families arriving with long-standing trusts must assess whether these structures still achieve their intended objectives once the family is resident in Italy. Sometimes a trust requires only minor adjustments; in other cases, it may need a deeper revision of the deed, governance, protector roles or distribution mechanisms.

A pre-immigration review ensures that the trust remains effective, understood by Italian authorities and aligned with the family’s long-term vision.

Holding companies and family business interests

Many wealthy families operate through holding companies in Switzerland, Luxembourg, the UK, the U.S., Dubai or other international hubs. These entities can play a central role in family governance, providing control, privacy and efficient management of both operating businesses and investment portfolios.

But once the family becomes resident in Italy, these structures must be evaluated under Italian tax and legal rules. Issues such as controlled foreign corporation rules, substance requirements, dividend taxation, exit strategies and succession planning become much more relevant.

A clear governance blueprint allows family members to understand who controls what, how decisions are made and how shares and voting rights will pass to the next generation. Succession in a civil law system requires precision; shares cannot simply be transferred informally. Governance documents—shareholder agreements, bylaws, family charters—must align with Italian rules to avoid disputes or unintended tax consequences.

Life insurance as a governance tool

International life insurance policies, especially those structured in Luxembourg or Switzerland, are often used by global families to unify governance, protect heirs and simplify succession planning. Under Italian rules, qualified life insurance contracts can enjoy favourable taxation, creditor protection and exemption from the Italian inheritance process.

But the policy must be compliant with Italian standards to achieve this. If a family structured its insurance policies before considering Italy, a review is essential. Italian law examines whether the policy is genuine insurance or simply an investment wrapper. The difference affects taxation, reporting and inheritance treatment.

When designed correctly, life insurance can become a central pillar of governance—linking liquidity planning, inheritance strategy and intergenerational stability.

Real estate and cross-border family dynamics

Property is often the most emotional asset within a family. A villa in Tuscany, an apartment in Milan or a historic property in Umbria can become the heart of the family legacy. But real estate also creates complex succession issues.

Italy’s forced heirship rules apply to Italian-situs real estate regardless of the owner’s nationality. For families who own property in different countries, understanding how these rules interact with foreign inheritance laws is essential. Governance planning can include:

allocation strategies for heirs,buy-sell mechanisms,joint ownership frameworks,and liquidity planning to avoid disputes.

The goal is to transform family real estate into a shared asset that strengthens family ties—not a source of future conflict.

Succession in Italy: clarity, planning and awareness

Italian succession law is highly structured. Spouses and children have reserved rights that cannot be ignored. If your global governance model relies on freedom of disposition, this may require adjustment. But Italy also allows for planning instruments that many families do not initially consider, such as patti di famiglia, strategic lifetime gifts, reorganisations of corporate ownership and cross-border wills coordinated through EU regulations.

A succession strategy should be documented in a way that is harmonious across jurisdictions, avoiding contradictory wills, misaligned trusts or inheritance plans that conflict with Italian forced heirship.

The advantage of a well-crafted plan is not only tax efficiency but family harmony during transitions.

Coordinating advisors across jurisdictions

A strong family governance system requires coordinated work. International families usually interact with multiple advisors—trustees, lawyers, wealth managers, tax specialists, corporate counsel and family office teams. When relocating to Italy, coordination becomes an essential part of governance.

The Italian rules must be understood by all advisors involved in the family’s global structure. Documents should be aligned, reporting systems consistent and communication channels clear. Governance is not a static project but a long-term framework that evolves with the family.

Italy becomes not just a place of residence, but the anchor for an integrated global system.

Turning Italy into a long-term family base

Italy offers an extraordinary combination of lifestyle, stability, cultural richness and predictable legal structures. For global families who integrate their governance model with Italian rules, the country becomes a strong, reliable base for future generations.

If you are considering Italy as your family’s new home and need support coordinating your global structures with the Italian system, we are here to help.

You can contact us privately at info@knotted.ch or via WhatsApp at +41 76 771 30 22.