Investor tax reporting services

Under Italian tax law, profits deriving from Italian, EU and EEA AIFs are generally subject to a 26% Withholding tax (WHT) rate. However, it is possible to benefit from exemptions.

Alternative PIR

For AIFs compliant with the Italian "PIR" regulation (so-called "Alternative PIR"), Italian investors can benefit from a full exemption on the profits realized by the fund up to 300k Euro of investment per year, for a maximum overall amount of 1.5M Euro).

The exemption applies only in case the investment is held for a minimum of 5 years and each investor can only hold one "Alternative PIR". 

In order to be considered compliant with the PIR regulation, the fund should respect certain investment requirements (such as 70% invested in Italian SMEs or EU/EEA SMEs with a permanent establishment in Italy).

Distribution reporting

From an Italian tax perspective, when an Italian individual investor holds an Italian, EU, EEA AIF fund, taxable income that may derive from such investment qualifies as "Income from Capital" (subject to a 26% WHT). On the contrary, Capital Repayments should generally not be subject to WHT. For this purpose, in case of interim cash distributions, the fund / its management company may provide a declaration stating the portion of "Income from Capital" (taxable) and the portion of "Capital Repayment" (non taxable).

Scope of services

  • Analysis for Alternative PIR regime;
  • Breakdown of the distributed amount to determine the portion of income from capital and capital repayment.


Regulatory reporting services

COVIP reporting for Italian pension funds - Circular COVIP n. 250 of 11 January 2013

Key Features

Target investors

Pension Funds




Compilation of a specific template (3 worksheets)


Standard excel format

Main features

COVIP, the Supervisory Board on pension funds, is the authority dedicated to overseeing the proper functioning of the supplementary pension system. 

Italian pension funds are required to monitor the economic exposure of their portfolio in line with rules on the investment criteria and limits of the assets of the pension funds. 

Italian pension funds, which are investors in investment funds, will ask the asset manager to provide them with a report including a detailed asset classification to meet their requirements. 

Quarterly and annually issued, this reporting is not mandatory per se. However, all funds targeting pension fund investors will have to comply with the COVIP requirements.


Contact us

Oliver Weber

Tax Partner, PwC Luxembourg

Tel: +352 49 48 48 3175

Christian Heinz

Tax Partner, Global Tax Compliance Leader, PwC Luxembourg

Tel: +352 621 33 2247

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