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Tax Specialist Group


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ITSG World Conference in Rome, October 21-24, 2025. The Westin Excelsior, Rome.

ITSG Conferences



Every year ITSG holds two conferences: an European conference and the worldwide annual conference.

ITSG 2024 Conference. Click on picture to see names

Above is the group photograph from the 2024 world-wide conference held in Toronto, Canada.

The conference is open only to ITSG members and a limited number of invited guests.

Below is a summary of the program for the conference in Rome — October 21, 2025.

Tuesday, October 21, 2025
5:00 - 7:30 P.M. Our local host firm Lipani Legal & Tax invites you to a reception at their office. (Complimentary).
Corso Vittorio Emanuele II, 284.
8:00 P.M. Join your colleagues for dinner at Restaurant Traiano overlooking the ancient Roman Forum. [Extra cost with registration].
Trojan’s Forum, 1b. Location is 25 minute walk from Lipani office.
Wednesday, October 22, 2025
SPECIAL INTEREST GROUP DAY
9:00 - 10:30 A.M.
Session A. (Trianon) Regulations in tax law
The importance of regulations, published rulings, and position papers issued by tax authorities in the world of tax is often assumed for practical reasons. But are they binding on taxpayers or followed by courts? The panel will discuss approaches in several countries. [Concurrent]
Session B. (Boncompagni). EU tax directives.
This session will provide practical and concise summaries of recent EU tax directives and how they affect tax advisers and their clients. Does the Unshelling directive have new life? [Concurrent].
10:30 - 11:00 A.M. BREAK
11:00 - 12:30 A.M.
Session C. (Trianon). Death and taxes: international problems.
Due to the variety of taxes that governments may seek to levy on gifts, bequests, and trust income, global families may suffer double or triple taxation on income and capital transfers. The panel will address recent experiences. [Concurrent].
Session D. (Boncompagni). The criminal responsibility of the tax advisor.
Where is the line drawn between aggressive but legal planning by tax advisers and participation of tax advisers in criminal conspiracies to evade tax by clients. Recent experience in the U.K., Denmark, Germany and other countries will be discussed. [Concurrent].
Borghese LUNCH
1:15 - 2:00 P.M.
Boncompagni		 Managing Partners Lunch.
For managing partners of member firms. Others are welcome to listen during this working lunch.
Each year we select a topic for discussion. This year’s topic is: :
Using Artificial Intelligence in our Practices; advantages and dangers.
2:00 - 3:00 P.M. Real estate structures.
Cross border investments in real property expose a foreign investor to many different tax risks, including income tax, capital gains tax, and estate or inheritance taxes. Planning solutions that work for local investors may not work for foreign investors. The panel will address real life problems, solutions, and horror stories.
3:00 - 3:15 P.M. BREAK
3:15 - 4:15 P.M.
Trianon 		Latam Special Interest Group.
Our Latam members will discuss an update on developments in selected Latam countries and a brief analysis of bilateral investment and double tax treaties in the region. All are welcome to attend.
4:30 - 6:00 P.M. Steering Committee Meeting.
(for Steering Committee members)
RECEPTION AND DINNER
Giardino d’Inverno Westin Excelsior
Reception 6:30 pm
Dinner 7:30 pm
Thursday, October 23, 2025
9:00 A.M.
Ludovisi		 Main Conference Commences.
Introductions and Welcome
09:15 - 10:15 A.M. Host Country - Italy.
Key aspects of the tax system of interest to international tax advisors.
10:15 - 11:00 A.M. New UK rules and Where are former “UK Non-Doms” going?
The UK has introduced new rules for non-doms and new residents to the UK. What are these new rules and is the UK still a potential destination for UHNW families? Further, where have the former “UK Non-Doms” gone and did they make the right move?
11:00 - 11:20 A.M. BREAK
11:20 - 12:20 P.M. OECD Developments.
What is the OECD now looking at and what may come next.
12:20 - 2:00 P.M. LUNCH
2:00 - 2:40 P.M. Redomiciliation of companies.
Sometimes moving a company to a different jurisdiction and converting it into a local company can avoid a lot of practical issues (for instance transfer taxes on disposal of real estate, realisation of gains). Other times, redomiciliation breeds immediate tax at the time of departure. Sometimes a change in tax residence is not recognized for tax purposes in the former state of residence. What are the issues involved in redomiciling? How are they addressed?
2:40 - 3:20 P.M. Taxation of Distributions from Private Wealth Structures.
Income, wealth, and inheritances taxes imposed on trusts and beneficiaries can vary from country to country. In many instances, the rules vary as to taxpayer, computation of amounts, and timing of taxable events. The panel will discuss client experiences encountered in practice.
3:20 - 4:10 P.M. Options on the Move.
Many people receive incentives for work over a period of time. How do you deal with the fact that they often work in several different countries before the option vests or is exercised? What are the risks to the individual? What is the exposure to the corporate employer? How do tax authorities know of the exercise of an option or the sale of shares acquired under the option?
4:10 - 4:30 P.M. BREAK
4:30 - 5:10 P.M. Non-tax treaties and agreements with an effect on tax.
A look at the international treaties and agreements between jurisdictions that don’t involve tax. Such examples include Human Rights, bilateral consular agreements, the EU, other international organisations and Business Investment Treaties.
GROUP photo (location to announce)
RECEPTION AND GALA DINNER
6:15 - 7:30 P.M. Restaurant Antica Pesa
Via Garibaldi, 18
Buses depart hotel at 7:00 p.m. sharp
Friday, October 24, 2025
09:00 - 10:10 A.M.
Ludovisi		 European Tax Update.
The always popular and fast paced update on European tax developments.
10:10 - 10:50 A.M. Entity classification.
Different classifications of entity/structures (such as hybrid entities, protected cell companies, usufructs, trust, foundations etc.) can result in hybrid situations or unclear tax arrangements. What types of arrangements/entities are there and what problems arise?
10:50 - 11:10 A.M. BREAK
11:10 A.M. - 12:00 P.M. Asia Tax Update.
An update on developments in selected Asian countries.
12:00 - 12:40 P.M. Holding Companies.
Do Holding Companies still have a role in international tax planning?
12:40 - 1:40 P.M. LUNCH
1:40 - 2:20 P.M. Residence and Passports.
What is next within the E.U. after the C.J.E.U. decision on citizenship by investment?
Current tax incentives throughout the E.U. and other countries are designed to attract the wealthy and also senior executives. Can the regulations proposed by tax authorities for these incentives be challenged by the C.J.E.U, and if so, what hurdles must be overcome?
2:20 - 3:00 P.M. U.S. Tax Update.
A fast-paced look at recent U.S. tax developments.
3:00 - 3:20 P.M. BREAK
3:20 - 4:20 P.M. The Great Debate.
Weaponising tax: does a country or organisation have the right to impose reprisal taxes or tariffs just because it does not like the tax system in another country? For instance, the OECD with UTPR, EU countries with DST and the USA with the originally proposed sections 899 and 891.
4:20 P.M. CONFERENCE ADJOURNS
5:20 P.M. WALKING TOUR.
A guided walking tour of ancient Rome. Weather permitting. Leaves from hotel lobby at 5:20 pm sharp [Complimentary].
8:00 P.M. INFORMAL DINNER.
Restaurant – Le Serre Barberini
Via Della Quattro Fontane, 13
(inside Barberini Palace)

[Walking tour ends at restaurant]
[Extra cost with registration].
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