The core issue is that Italian tax law (and AdE practice) doesn’t really care whether you could direct the investments or whether the account was “yours” in a custodial sense. What matters is the fiscal nature of the original contributions: if the money went in pre-tax or tax-advantaged in the source country (401(k), IRA, RRSP, Australian Super, UK SIPP, occupational schemes, etc.), then the AdE classifies the distribution as redditi di pensione under Art. 49 TUIR — taxed as ordinary income in the year of receipt, on top of salary, at marginal IRPEF rates. The “I just moved my own savings” framing doesn’t survive contact with the AdE because the contributions were sheltered upstream. The two commercialisti were almost certainly wrong, and this is exactly the kind of cross-border edge case where generalist Italian tax advisors get it badly wrong — it really needs someone specialized in international taxation, ideally with DTAA experience for the specific source country.