George Clooney has famously referred to his life in Italy as a form of ‘therapy’ – and he’s not the only high-profile person to recognise its benefits. A growing cohort of the wealthy and well-known have followed suit and moved to the Big Boot, from vice-chair of Goldman Sachs Richard Gnodde to Egypt’s richest man and co-owner of Aston Villa, Nassef Sawiris.
The attraction is easy to understand. The food, the landscape, the pace of life and, it must be said, the favourable flat tax regime for wealthy foreigners. Mostly, la dolce vita speaks for itself.
As more HNWs have relocated to Italy in recent years, the infrastructure around them has followed. Milan in particular has seen the arrival of new private members’ clubs alongside a wave of luxury real estate developments and hotel openings such as The Carlton, a Rocco Forte Hotel.
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Private wealth services have followed suit, with firms including Julius Baer, Ares Management and Charles Russell Speechlys all opening Milan offices in the past couple of years. Competition for places at the country’s top international schools has intensified and, with wealthy families flocking to the nation, family law is yet another area of demand that has emerged within the burgeoning private wealth ecosystem.
‘When that concentration of wealth is accompanied – as it increasingly is – by tax-driven relocations, you inevitably see demand for family law advice increases,’ says Maria Fiorito, a partner at Vardags who is dual-qualified in the UK and Italy. Fiorito leads the firm’s Italian office, which opened its Milan office in January.
According to the latest numbers published by the Italian Revenue Agency, nearly 4,000 HNW individuals moved to Italy between 2020 and 2023, with Milan emerging as the most popular destination, followed by Rome. The influx of new wealthy residents under Italy’s flat tax regime is expected to bring around €21 billion in total wealth into the country, according to projections by Vardags. And as globally mobile individuals continue to put down roots, Fiorito notes that their presence is naturally creating ‘a pipeline of complex, multi-jurisdictional family law work that will continue to develop over the next decade’.
That shift, as Armando Cecatiello, an Italian family lawyer working between Milan and London, tells Spear’s, reflects something broader: ‘Italy is no longer simply a lifestyle destination. It is becoming a jurisdiction where UHNW families live, invest, educate their children and structure their tax and succession planning.’
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This is reflected by the arrival of several UK-headquartered law firms, including Charles Russell Speechlys, which opened a Milan office in late 2024, joining Clifford Chance and Withers in the city.
A key change that has come with this movement of people, Fiorito says, is ‘complexity’. Previously, even at the top end, family law cases in the country were likely to be relatively narrow disputes about separation or maintenance, but the influx of international UHNW families means that there is no shortage of matters involving corporate structures, succession, tax residency, trusts and property spread across different countries.
Many clients, Fiorito says, focus heavily on the tax advantages of moving to Italy without fully considering which jurisdiction would have authority if the marriage were to break down. In a post-Brexit context, where the interaction between English and European jurisdictions is less predictable than it once was, this can be decisive.
‘The anchoring of a divorce in one or the other jurisdiction could make a significant difference to the financial outcome,’ she explains, which makes early planning essential. Under EU law, the Italian courts’ jurisdiction is mainly based on the parties’ ‘habitual residence’ and shared Italian nationality. However, this does not exclude other factors that may be relevant in non-EU countries, such as domicile in England and Wales.
UHNW couples should also consider prenuptial agreements. Some assume that agreements drafted in London or New York will simply ‘travel’ with them, but this isn’t always the case in practice. Italy has historically been cautious about recognising prenups, particularly where they are seen to predetermine the financial consequences of divorce.
Another significant risk lies in Italy’s matrimonial property regime. Couples who marry abroad and later relocate may find that their expectations – likely formed in the context of English law – do not necessarily align with Italian law. Under the Italian regime of comunione legale (‘communion of assets’), property acquired during the marriage can, in broad terms, be treated as jointly owned regardless of how it is formally titled.
Nicola Saccardo, the head of the Italian practice at Charles Russell Speechlys, explains that while both English law and Italy’s comunione legale can result in a 50:50 split on divorce, ‘they operate in fundamentally different ways in practice’. In Italy, the division is ‘largely automatic’, he tells Spear’s: it reflects what was jointly owned during the marriage under a pre defined legal regime. In England, by contrast, the court has broad discretion to reallocate wealth in pursuit of fairness, even if assets are held in one spouse’s sole name.
‘This distinction becomes critical in more complex cases,’ Saccardo adds. ‘For example, assets such as pre-marital wealth, inherited property or business interests may fall outside the comunione legale but can still be taken into account by English courts. As a result, the same couple could walk away from divorce with significantly different outcomes depending on jurisdiction, making forum choice a key strategic consideration in international cases.’
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For Saccardo, ‘the most effective tool available within the Italian system is electing separazione dei beni (separation of assets) before a notary’.
International families can also be caught out on succession planning. Unlike in England, where people generally have broad freedom to decide who inherits their estate, Italian law reserves portions of an estate for spouses, children and in some cases even parents – regardless of what a will says. For families arriving from common law jurisdictions, he says, this can come as a ‘profound shock’.
Saccardo gives the example of an English individual who leaves their entire estate to a spouse while excluding children from a previous marriage. That arrangement may be valid in England, but if Italy becomes the person’s habitual residence, those children could still be entitled to a share of the estate under Italian law. Without the right planning in place, he warns, the will can effectively be overridden.
There are other differences, too. Lawyers who act internationally say that Italian courts are slower, disclosure is more limited, and prenups are treated with far more uncertainty than in common law jurisdictions.
Although the influx of wealth and wealthy people has happened, the infrastructure needs time to catch up, says Cecatiello. He points to the need for ‘a more integrated ecosystem around private wealth disputes’. There are ‘excellent Italian family lawyers’, says Fiorito, but she also notes a shortage of practitioners who are genuinely fluent in both Italian and English family law as well as international private wealth structures.
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