🇮🇹Italy: Flat Tax for New Residents (€300k from 2026)

Concept

Italy offers one of Europe's best-known regimes for wealthy relocators — the "new residents regime" (regime dei neo-residenti, Art. 24-bis of the Tax Code, TUIR). Instead of the standard progressive tax, a new resident pays a fixed sum (flat tax) on all foreign income — regardless of its size — for up to 15 years.

This is a substitute tax: it closes off the Italian tax on foreign income but does not make that income invisible to other countries.

History: Why Italy Created This Regime

The regime did not appear out of nowhere. It was introduced by the 2017 Budget Law (Legge 232/2016, Article 24-bis TUIR) — at a moment when Britain was tightening its non-dom rules and wealthy foreigners were looking for a predictable alternative in Europe. Italy offered what Switzerland had done for decades through its lump-sum tax: pay a known sum in advance and not account for every euro of foreign income.

The bet paid off: entrepreneurs, athletes and large rentiers were drawn to the regime. Popularity turned into higher prices — the entry ticket was raised every few years on a simple logic: demand exists, so the price can rise without losing the flow of applicants. A one-off relief thus became a permanent, but ever more expensive, budget instrument.

How the Flat Tax Works

• amount: a fixed tax on all foreign income (the rate depends on the year of entry into the regime);
• duration: up to 15 years, renewed automatically each year;
• family: a surcharge for each included family member, set by the date that member transferred residence (Article 24-bis TUIR, comma 2): €25,000 for transfers before 1 January 2026, €50,000 from that date;
• coverage: dividends, interest, capital gains, foreign real estate, etc.;
• exemption from foreign-asset monitoring (the RW declaration) and from taxes on foreign assets (IVIE/IVAFE);
• exemption from inheritance and gift tax on foreign assets during the regime period;
• Italian income is taxed under the standard progressive tax (IRPEF, up to 43% plus local surcharges).

Anti-abuse clause: capital gains from "qualified" participations (partecipazioni qualificate) in the first 5 years of the regime fall outside the flat tax and are taxed under the ordinary rules.

Who Can Enter

The main condition: not having been an Italian tax resident for at least 9 of the last 10 years before relocating. The regime is optional and is chosen when transferring tax residency to Italy. Economically it makes sense with substantial passive foreign income, when the fixed sum is more advantageous than the progressive rate.

How to Arrange It and When to Pay

The flat tax is not assigned automatically — you elect it in the annual tax return (Redditi PF, section NR). Before the first entry it is sensible to request an advance ruling from the tax authority (interpello): it confirms eligibility for the regime and removes disputes for years ahead.

Payment is made once a year as a single sum, by the deadline for the annual IRPEF balance (by 30 June), through form F24. There is no instalment plan and no "right to a mistake": missing a payment means losing the regime with no reinstatement. The tax authority initially allowed combining the flat tax with the new regime for inbound workers (D.Lgs 209/2023), but the window is closing: Art. 2 of Decree-Law No. 38 of 27 March 2026 (in force 28 March 2026, converted by Law No. 88 of 22 May 2026 — so this is settled law, not a decree still awaiting conversion) expressly bans cumulating Art. 24-bis TUIR with Art. 5 of D.Lgs 209/2023 for anyone transferring tax residency to Italy from 1 January 2027. Those who transfer by 31 December 2026 keep the combination.

Immigration Component: How to Obtain Residency

The flat tax is a tax regime, not a visa. To become a tax resident, you must actually transfer residency (more than 183 days or your centre of life). Routes:

• EU/EEA citizens: no visa is required, registration of residency is enough.
• Investor Visa (the "golden visa"): €250,000 in an innovative startup, €500,000 in an Italian company (S.r.l.), €1 million as a charitable donation, or €2 million in government bonds. The visa is independent of the flat tax: it grants residency, while the tax is calculated separately.
• Elective residence visa (for the financially independent): passive income of no less than €31,000/year for the main applicant, increased by at least 20% for an accompanying spouse (about €37,200 for a couple) and by at least 5% for each child (about €1,550), housing and health insurance; no right to work in Italy. This is not a per-person threshold; the requisite is point 13 of Annex A to Interministerial Decree No. 850 of 11 May 2011 (Definizione delle tipologie dei visti d'ingresso e dei requisiti per il loro ottenimento — Definition of entry visa types and the requirements for obtaining them), which fixes the amount at three times the annual figure in Table A of the Interior Ministry Directive of 1 March 2000; consulates may require more than the minimum.

Context: How It Compares to Other Regimes

A fixed sum regardless of income size makes the regime worthwhile with very large foreign income — where a progressive scale would take far more. The market neighbours are built differently. Greece copied the Italian model almost literally: the same €100,000 a year. Switzerland has for decades levied a lump-sum tax on expenditure rather than on income. Spain, under the Beckham law, grants a flat 24% up to €600,000, but the relief is partial: under Art. 93.2.b) LIRPF employment income (rendimientos del trabajo) is taxed worldwide, and Art. 17.2.a) treats pensions as such income — «en todo caso». The United Kingdom abolished non-dom status in April 2025 and left newcomers only a four-year relief (FIG). Against this backdrop Italy wins on a 15-year length and predictability, but after 2026 it carries the highest entry price. We have collected the full map of such regimes separately.

Risks and What to Consider

• the flat tax does not close off the taxes of the country you leave: controlled foreign companies (CFC), exit tax, the treaty tie-breaker, citizenship-based taxation;
• you must genuinely become an Italian resident (centre of life), otherwise the regime does not work;
• "qualified" participations in the first 5 years are outside the regime;
• the rise of the rate to €300,000 shifts the break-even threshold upward;
• the fixed sum is paid annually regardless of whether there was any income.

Athletes and the Flat Tax: What Survived D.Lgs. 209/2023

Until 2024 a professional athlete had a dedicated way into the relief. Art. 5(2-quater) of the "growth decree" (D.L. 34/2019, converted by L. 58/2019) inserted comma 5-quater into Art. 16 of D.Lgs. 147/2015: for sportspersons employed under L. 91/1981 who transferred residency from 2020 onwards, half of the Italian income entered the IRPEF base (against only 30% for ordinary impatriati), the enhanced southern relief did not apply, and electing the regime carried a contribution of 0.5% of the taxable base earmarked for youth sport development. The term was 5 tax periods.

Art. 5(9) of D.Lgs. 209/2023 (applicable from 2024) repealed both Art. 16 of D.Lgs. 147/2015 and the sports-specific commi 2-bis to 2-quinquies of Art. 5 of D.L. 34/2019. The new impatriati regime grants a 50% exemption (60% where a minor child is involved), but caps qualifying income at €600,000, runs for 5 tax periods, and requires 3 years of prior non-residence (6–7 where the move is inside the same group), a commitment to remain resident for 4 years and — crucially — "high qualification or specialisation" as defined by D.Lgs. 108/2012 and D.Lgs. 206/2007. There is no separate sports track any more: a footballer without a tertiary degree fails that test, while athletes holding a relevant degree are formally in scope but the point is contested and decided case by case. Transitional rule: the old rules survive for those who registered residency in Italy by 31 December 2023 and, for sports employment relationships, for those whose contract was signed by that same date.

What remains for an athlete in 2024–2026 is Art. 24-bis TUIR. But the flat tax only closes foreign income: the salary from an Italian club is employment income under L. 91/1981 and D.Lgs. 36/2021, taxed on the ordinary IRPEF scale of up to 43% plus surcharges. No official confirmation exists for the tax position of any named athlete — that is tax secrecy; the characterisation of image-rights income must be analysed separately.