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

Concept

Italy offers a regime for wealthy individuals relocating to the country — 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 replaces Italian tax on foreign income but does not exclude that income from other countries' tax oversight.

Status and figures as of 20 August 2026. Since the regime was introduced in 2017 the charge has been raised twice, and the cohorts are separated not by the year of the return but by the date on which residence is transferred to Italy (Article 43 of the Civil Code).

€100,000 — for those who transferred civil residence to Italy on or before 10 August 2024: Article 2(2) of Decree-Law 113/2024 applies the increase only to transfers after its entry-into-force date. €200,000 — under Article 2 of that decree (Gazzetta Ufficiale No. 186 of 9 August 2024, in force 10 August 2024, converted with amendments by Law No. 143 of 7 October 2024) — for those transferring residence after that date. €300,000 — under Article 1, paragraph 25 of Law No. 199 of 30 December 2025 (the 2026 Budget Law, published in Gazzetta Ufficiale No. 301 of 30 December 2025, in force 1 January 2026) — for those transferring residence from 1 January 2026: paragraph 26 keys the new figures to the date of that transfer. Earlier entrants keep their own figures (grandfathering). The same paragraph 25 raised the surcharge per family member from €25,000 to €50,000, on the same cohort rule; Decree-Law 113/2024 had left it untouched.

The provision cited is Article 24-bis of the Consolidated Income Tax Act (Testo unico delle imposte sui redditi, TUIR), approved by Presidential Decree No. 917 of 22 December 1986. It applies through 31 December 2026: the new Consolidated Income Tax Act (Legislative Decree No. 117 of 19 June 2026, Gazzetta Ufficiale No. 152 of 3 July 2026, Ordinary Supplement No. 26) moves the regime to Article 246 and the pensioners' regime to Article 247, applies from 1 January 2027 (Article 377) and from that date repeals Articles 1 to 191 of Presidential Decree 917/1986 (Article 376(1)(e)) — which is why Normattiva already marks Article 24-bis as repealed. Comma 2 of Article 246 states the current figures, €300,000 a year and €50,000 per family member; the rules that key the lower amounts to earlier transfer dates sit in paragraph 26 of Law 199/2025 and Article 2 of Decree-Law 113/2024, neither of which is on the repeal list. Comma 7 of Article 246 carries the cumulation ban into the new code: the option cannot be combined with the impatriati regime (Article 225, formerly Article 5 of D.Lgs. 209/2023) or with commi 1–5 of Article 226 on returning researchers.

History: Why Italy Created This Regime

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. The Italian model provided for a known sum in advance without accounting for every euro of foreign income — an approach Switzerland had applied for decades through its lump-sum tax.

The regime attracted entrepreneurs, athletes and large rentiers. Popularity was accompanied by higher charges: the tax amount was raised every few years, with strong demand expected to sustain the flow of applicants. The relief thus became a permanent budget instrument with an increasing cost.

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.

Eligibility

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.

Election and Payment

The flat tax does not apply automatically — the taxpayer elects it in the annual tax return (Redditi PF, section NR). Comma 3 of Article 24-bis TUIR requires the option to be exercised after obtaining a favourable reply to a specific request for an advance ruling (istanza di interpello) filed with the Agenzia delle Entrate under Article 11(1)(f) of Law No. 212 of 27 July 2000, within the deadline for the return for the tax period in which residence is transferred to Italy, and it takes effect from that same period. The ruling confirms eligibility for the regime and removes disputes for years ahead.

From 2026 the interpello is also covered by tax-information exchange rules. Directive (EU) 2023/2226 (DAC8) rewrote Article 3(14) and Article 8a(4) of Directive 2011/16/EU: an advance ruling on whether a natural person is tax resident in the issuing state is now expressly a cross-border ruling, and automatic exchange extends to rulings on the tax affairs of individuals. The exchange covers a ruling issued, amended or renewed after 1 January 2026 where the amount of the transaction or series of transactions exceeds €1,500,000 and that amount is stated in the ruling itself, or where the ruling determines tax residence in the issuing state. An interpello under Art. 24-bis TUIR answers precisely that second question by its subject matter — the applicant demonstrates that they were not an Italian resident for 9 of the last 10 years — and so enters the exchange without reference to any amount. The Agenzia delle Entrate's answer goes into the EU central directory and is visible to the tax administrations of every Member State, including the one the applicant left.

Rulings issued earlier fall outside the provision: a 2021 interpello that simply remains in force is not exchanged under DAC8. Amendment or renewal of the ruling after 1 January 2026 makes the entire document subject to exchange. Planning can rely on the confirmation remaining private only until the first such amendment or renewal.

Payment is made once a year as a single sum, by the deadline for the annual IRPEF balance (by 30 June), through form F24. Instalments and correction of a missed payment are not provided for: 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 this possibility is limited in time: 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) 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. Tax residence requires an actual transfer of residency (more than 183 days or the 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 tax under a progressive scale would be substantially higher. Other regimes have different conditions. 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). Italy's advantages are its 15-year term and predictability, but after 2026 it has the highest cost of participation. Italy, Greece, Switzerland, Spain and the United Kingdom are compared with thirteen other regimes — what is exempt, term, cost of participation, presence, prior non-residence, family surcharge and election deadline — in special tax regimes, where a worked example on €2,000,000 of passive income compares the €300,000 charge with the other regimes. The investor visa usually used by a flat-tax holder is compared with the other European investor routes in investor routes in Europe.

Risks and What to Consider

• the flat tax does not replace taxes imposed by the country of departure: controlled foreign companies (CFC), exit tax, the treaty tie-breaker, citizenship-based taxation;
• the taxpayer 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 professional athletes had separate conditions for 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 "high qualification or specialisation" as defined by D.Lgs. 108/2012 and D.Lgs. 206/2007. There is no longer a separate regime for athletes: 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. However, the flat tax covers only 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.