Italian Inheritance & Trust Services for Foreign Nationals
Protect your legacy in Italy — wills, trusts and cross-border estate planning drafted by a notary, in English, fully compliant with Italian and EU law.
Italian law governs all assets located in Italy, regardless of the owner’s nationality. A certified Italian notary is the only professional legally authorized to draft Italian wills, register trusts and notarize the transfer of inherited Italian assets — so foreign nationals can plan and settle Italian succession with full legal validity.
Key Takeaways
- Owning assets in Italy does not automatically mean that Italian law governs the entire succession.
- The applicable succession law is generally determined by the deceased’s habitual residence, unless a valid choice of the law of nationality has been made.
- Foreign nationals can plan in advance how their Italian and international assets should be coordinated within their estate.
- Wills involving more than one jurisdiction should be assessed in light of the applicable succession law and the formal requirements of each relevant country.
- Trusts involving Italian assets require careful legal and tax analysis before they are established or funded.
- Italian forced-heirship rules are relevant when Italian succession law applies, but should not be assumed to apply solely because an asset is located in Italy.
- Cross-border estate planning should coordinate Italian notarial requirements with advisers in the other jurisdictions involved.
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If you own anything in Italy, Italian law applies Real estate, a bank account, shares in an Italian company — any asset located in Italy falls under Italian succession rules. Where you live, and what your home country’s law provides, does not override this.
Plan early, or your heirs pay for it Acting without a clear plan, or too late, exposes your estate and heirs to consequences that are difficult and costly to reverse. The right instrument — will, trust or structured transfer — chosen for your case protects your beneficiaries.
Our Inheritance & Estate Planning Services
Italian Wills for Foreign Nationals
Planning and preparation of wills involving Italian assets and international family circumstances.
Choice of Succession Law
Assessment of the applicable succession law and, where available, the possibility of choosing the law of nationality under EU Regulation No. 650/2012.
Trusts Involving Italian Assets
Notarial and cross-border coordination for trusts involving Italian property, family wealth or other Italian assets.
Cross-Border Estate Planning
Coordination of Italian assets with wills, succession arrangements and professional advisers in other jurisdictions.
Family & Asset Protection Planning
Assessment of succession structures involving spouses, children, beneficiaries and family-held assets.
Family & Asset Protection Planning
Assessment of succession structures involving spouses, children, beneficiaries and family-held assets.
Frequently Asked Questions — Italian Inheritance & Trust
Does Italian forced heirship apply to foreign nationals who own property in Italy?
Not automatically. The fact that a foreign national owns property in Italy does not by itself determine which succession law governs the estate.
Under EU Regulation No. 650/2012, the succession is generally governed by the law of the deceased’s habitual residence at the time of death, unless a valid choice of the law of nationality has been made. Italian forced-heirship rules become relevant when Italian succession law applies to the succession.
Can an American choose US law to govern their succession?
EU Regulation No. 650/2012 allows a person to choose the law of the State whose nationality they hold to govern their succession.
For US citizens, however, the United States has multiple state legal systems, so determining the relevant law and how the choice should be drafted requires a case-specific assessment.
Should a foreign property owner make an Italian will?
An Italian will is not automatically required simply because someone owns property in Italy.
However, foreign owners of Italian assets may benefit from reviewing how their existing will interacts with Italian property, EU succession rules and any other jurisdictions involved in their estate.
In some cases, coordinated wills in different jurisdictions may improve clarity and simplify future administration.
Can a US or UK will be used in Italy?
A foreign will may be recognised and used in Italy if the applicable legal and formal requirements are satisfied.
Its effectiveness should be assessed in light of the applicable succession law, the form of the will, the jurisdictions involved and the Italian assets affected.
Foreign documents may also require additional formalities before they can be used in Italy.
What law applies if I own property in Italy but live abroad?
Owning property in Italy does not automatically make Italian succession law applicable to your entire estate.
The general rule under EU Regulation No. 650/2012 is that the succession is governed by the law of the deceased’s habitual residence at the time of death, subject to specific exceptions and any valid choice of the law of nationality.
Can I have both an Italian will and a will in another country?
Potentially, yes. International estate planning may involve more than one will, but the documents must be carefully coordinated to avoid one will unintentionally revoking or conflicting with another.
The appropriate structure depends on the assets, countries involved and the succession law that is expected to apply.
Can a trust hold Italian property?
Trusts can interact with Italian assets, but the legal and tax treatment must be assessed carefully.
EU Regulation No. 650/2012 does not regulate the creation, administration or dissolution of trusts. A trust involving Italian property therefore requires separate analysis of the trust instrument, applicable law, Italian property rules, registration requirements and tax consequences.
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When should international estate planning be reviewed?
Estate planning should be reviewed when significant personal or financial circumstances change, including relocation to another country, acquisition or sale of Italian property, changes in nationality or residence, marriage or divorce, changes in family structure, creation of trusts or significant changes in the composition of the estate.
Cross-border plans should also be reviewed periodically to ensure that wills and other arrangements remain coordinated across the jurisdictions involved.