Bare Ownership and First-Home Tax Benefits: Can You Really Qualify? What to Know Before Bu

LT Immobili & Design 27 August 2026

Can you purchase bare ownership of a property and still benefit from Italy’s first-home tax relief? It is a less unusual question than it might seem, particularly as bare ownership is attracting interest not only from investors, but also from families and buyers taking a medium- to long-term approach to property ownership.

In the real estate market, some transactions can initially appear highly technical. Bare ownership — nuda proprietà in Italian — is certainly one of them.

The basic principle is relatively straightforward: you acquire ownership of a property today, while another person retains the right to use or live in it. Understanding the financial, tax and patrimonial implications, however, requires a little more attention.

And this is where one of the most common questions arises:

Can someone purchasing bare ownership qualify for Italy’s first-home tax benefits?

In general, the answer is yes. But, as is often the case with Italian property transactions, there are conditions that should be understood before proceeding.

When purchasing the bare ownership of a property, you become its legal owner without immediately acquiring the right to use it.

That right remains with the usufructuary, who may continue to live in or use the property in accordance with the terms established in the deed.

The bare owner therefore holds the ownership right, while the usufructuary retains its use. When the usufruct ends — generally upon the death of the usufructuary in the case of a lifetime usufruct — the two rights are reunited and the bare owner automatically acquires full ownership.

It is precisely this separation between ownership and use that determines the economic logic of the transaction.

For the seller, it can provide a way of releasing part of the value tied up in a property while continuing to live there. For the buyer, it can offer the opportunity to acquire a property at a value generally lower than its full ownership value, in exchange for giving up immediate use.

Yes. The purchase of bare ownership can qualify for Italy’s first-home tax benefits, provided the buyer meets the applicable legal requirements.

Italian tax rules do not restrict the benefit exclusively to the purchase of full ownership. The Italian Revenue Agency expressly includes transactions involving bare ownership, usufruct, rights of use and habitation among those that may qualify for the prima casa tax regime.

The fact that the buyer cannot immediately live in the property does not therefore, in itself, prevent access to the tax benefit.

The usual requirements, however, remain essential.

The property must not fall within the cadastral categories A/1, A/8 or A/9, which are excluded from the benefit. The buyer’s ownership of other properties must also be assessed, together with the requirement concerning residence in the municipality where the property is located, where applicable.

Particular attention should also be paid where the buyer already owns another property purchased using first-home benefits, as the rules governing a subsequent subsidised purchase need to be considered carefully in light of the individual circumstances.

For this reason, before structuring a bare ownership transaction, the buyer’s position should always be reviewed with the notary and the professionals involved in the purchase.

This is probably where most of the confusion arises.

A buyer may reasonably wonder how a property can qualify as a “first home” when the usufructuary may continue living there for many years.

The key point is that first-home tax relief and the immediate physical availability of the property are not the same thing.

For tax purposes, what matters is the property right being acquired and compliance with the conditions established by law. The existence of a usufruct does not cancel the ownership right acquired by the bare owner.

Therefore, the buyer does not necessarily need to be able to move into the property immediately in order for the acquisition of bare ownership to qualify for the first-home tax regime.

It may sound like a technical distinction, but it is fundamental to understanding how this type of transaction works.

This is where the subject becomes particularly interesting.

The value of bare ownership is lower than the value of full ownership because the buyer cannot immediately use the property. The economic value attributed to the usufruct and bare ownership is determined by a number of factors, including the age of the usufructuary and the relevant fiscal criteria.

Put simply, the greater the value attributed to the usufruct, the lower the value of the bare ownership.

But it would be misleading to describe this difference simply as a “discount”.

The buyer is effectively exchanging part of the purchase price for time: paying less today in return for giving up immediate use of the property.

It is therefore fundamentally different from purchasing a conventional property that is immediately available.

Bare ownership can make particular sense when the buyer does not need to use the property immediately.

It may form part of a broader wealth-planning strategy, for example when purchasing a property today with a view to its role within a family’s assets in the future.

It can also be considered when planning ahead for children or other family members, or as a long-term investment in locations where quality property is scarce and demand remains structurally strong.

The central question, however, is always the same: the purchase price must be assessed in relation to time and to the characteristics of the usufruct.

Simply comparing the price of bare ownership with the asking price of a vacant property on the open market is not enough.

Economically, they are two different assets.

This is particularly relevant when considering [how much a property’s location really affects its market value]. With a longer investment horizon, location, micro-location and characteristics that are difficult to replicate can become even more important.

Bare ownership should never be interpreted simply as “buying a house at a discount.”

Before purchasing, it is important to understand precisely which right is being acquired, how the usufruct has been valued and which obligations will remain with each party.

The allocation of property expenses between the bare owner and the usufructuary, for example, deserves careful consideration. The same applies to future works on the property, the patrimonial consequences of the transaction and the specific terms of the usufruct.

There is also the usual need to verify the property from an urban-planning, cadastral, documentary and tax perspective.

These checks help explain why apparently straightforward property transactions can sometimes become more complicated as they progress. We explored this subject in greater detail in [why some real estate negotiations collapse at the last moment].

The objective should not simply be to reach completion, but to reach it with a clear understanding of exactly what is being purchased.

Bare ownership may qualify for first-home tax benefits, provided all the legal requirements are satisfied.

The presence of a usufructuary — and therefore the buyer’s inability to use the property immediately — does not automatically exclude the benefit.

What needs careful assessment is the buyer’s individual position, including any other properties owned, the cadastral classification of the property, residence requirements where applicable and the correct tax structure of the transaction.

And it is worth remembering that the issues surrounding a property purchase do not necessarily end when the deed is signed. Costs, practical requirements and subsequent property management are topics we have also explored in [what happens after completion: costs, timing and what buyers should really know].

In real estate, the mistake is not asking technical questions.

The mistake is approaching a complex patrimonial transaction with an overly simple perspective.

Bare ownership can be an intelligent choice, but it should form part of a clear strategy: fiscal, property-related, financial and family-oriented.

In our work, we often see buyers focusing primarily on the difference between the price of full ownership and the price of bare ownership.

But price is only one part of the transaction.

The usufruct, the potential time horizon, the quality and location of the property, taxation, the obligations of the parties and, above all, the role that property is expected to play within the buyer’s assets over the coming years all deserve consideration.

A property should not be assessed only by what it costs today.

It should also be assessed by the role it may play tomorrow.

In an increasingly selective property market, purchasing bare ownership with first-home tax benefits in Italy can represent a genuine opportunity.

But there is no automatic advantage.

There are properties, financial circumstances and personal objectives that can make this structure particularly attractive. In other cases, waiting many years before obtaining full use of the property may simply not be consistent with the buyer’s needs.

Every opportunity should therefore be analysed methodically.

Because the difference between an apparently attractive purchase and a genuinely strategic property decision often lies in the quality of the analysis carried out at the beginning.

This article is intended for general information purposes only. The individual buyer’s tax position and eligibility for first-home benefits should always be verified with the notary and the relevant professional advisers before completion.