02.4004.4318
CALL US!
8:30 - 17:30
Mon-Fri

Categoria: Expats

Italy’s Flat Tax and Impatriati Regimes: The 2026 Window to Combine Both Closes from 2027

For several years, two of Italy’s most powerful inbound tax regimes — the non-dom flat tax for new residents and the new impatriati regime for inbound workers — could be applied together by the same taxpayer. That combination has produced striking outcomes for high earners: foreign passive income capped at a flat annual fee, and Italian-source employment or self-employment income taxed on only half of its amount. Decree-Law 38 of 27 March 2026 has now closed that door. From the 2027 tax year, anyone transferring tax residence to Italy must choose between the two regimes. Anyone who establishes Italian residence by 31 December 2026 keeps the combination intact for the full statutory duration of both regimes.

How the two regimes complement each other

The non-dom flat tax, governed by Article 24-bis of the Italian Income Tax Code, allows new residents to pay a fixed annual amount on all foreign-source income, regardless of size. The lump sum currently sits at €300,000 per year for the main applicant and €50,000 for each family member, for up to fifteen years. The regime targets high-net-worth individuals with significant offshore investments, dividends, capital gains, royalties, or rental income from abroad.

The new impatriati regime, introduced by Article 5 of Legislative Decree 209/2023, addresses a different tax base: Italian-source employment or self-employment income. Eligible inbound workers exclude 50% of that income from the IRPEF base for five years, with a 60% exemption available for parents who relocate with minor children. The annual income cap is €600,000.

Because the two regimes carve up the income map without overlap, combining them has been legitimate since the 2024 reform. The Italian Revenue Agency confirmed the cumulability in late-2025 guidance, treating the legislative silence on the point as an implicit green light. That silence is now over.

What the new rule actually says

DL 38/2026 introduces an explicit ban on cumulation, but only on a forward-looking basis. Taxpayers who establish Italian tax residence by 31 December 2026 continue to apply both regimes side by side for the full statutory duration of each. The protection is permanent and is not a phase-out. Taxpayers who transfer tax residence to Italy from 1 January 2027 onwards may elect either the flat tax or the impatriati regime, but not both. The election will be effectively binding for the duration of whichever regime is chosen.

The regime for professors and researchers is unaffected and remains separately combinable with other incentives.

What this means in practice

For anyone weighing an Italian move, the practical question is whether to bring it forward so the residence transfer takes effect before 2027. Italian tax residence is established when, for the majority of the tax year (more than 183 days), the individual maintains residence, domicile, or registered presence in Italy. For a 2026 move, this typically requires physical relocation by early July 2026 at the latest, supported by registration with the local anagrafe and consistent evidence that the personal and economic centre of life has shifted.

The combination is most valuable for taxpayers who have substantial foreign passive income — which the flat tax shelters at a flat €300,000 — and who will earn significant Italian-source professional or executive income, which the impatriati regime taxes on only half of its amount. For taxpayers whose profile is heavily weighted to only one of these two income streams, the choice imposed from 2027 will have a more limited financial impact, but the calculation should still be run carefully before any decision.

A Note for U.S. Citizens

U.S. citizens remain subject to worldwide taxation by the IRS regardless of where they reside. The flat tax can be treated as a creditable foreign tax in Italy, but its lump-sum nature complicates the per-country and per-basket allocation of the Foreign Tax Credit on Form 1116. Pairing it with the impatriati regime — under which half of Italian-source income is exempt from IRPEF — typically lowers the Italian tax actually paid on that portion, which in turn reduces the credit available against U.S. tax. In some scenarios this mechanically transfers part of the Italian saving into additional U.S. tax. A bilateral simulation, year by year and for the full intended duration of the regimes, is indispensable before relying on the combination as a planning strategy.

Final Considerations

The 2026 deadline is firm but the planning is not always simple. Establishing Italian tax residence, securing the flat tax election, and documenting eligibility under the impatriati regime are three distinct processes, each with its own timing and evidentiary requirements. For internationally mobile taxpayers considering Italy, this calendar year is the last opportunity to lock in the most generous version of the framework. Specialist advice that integrates both Italian and home-country tax positions is strongly recommended before any commitment is made.

The Italian Impatriati Regime in 2026: A Practical Overview for Workers Relocating to Italy

The Impatriati Regime is Italy’s main preferential tax incentive for qualified professionals who move their tax residence to the country. Restructured in 2024 and confirmed for 2026, it reduces the taxable base of Italian-source employment and self-employment income for a set number of years. Compared with the pre-2024 version, the current regime is more selective: lower exemption, shorter duration, stricter eligibility, and an income cap. ( FOR FULL DETAILS CLICK HERE )

Who Can Access the Regime

To qualify in 2026, an individual must simultaneously meet five conditions. The first is the transfer of tax residence to Italy under Italian domestic rules. The second is not having been an Italian tax resident in the three tax years preceding the transfer; this look-back period is extended to six years, or seven in some cases, if the worker continues to work in Italy for the same employer or the same group they worked for abroad.

The third condition is a commitment to remain an Italian tax resident for at least four years: losing residence earlier triggers recapture of the benefit with interest. The fourth is that work must be performed mainly in Italy — more than 183 days in the tax year. The fifth, and most restrictive, is the high qualification or specialization requirement: the worker must hold a qualification recognised under EU rules on regulated professions or on highly qualified employment (the EU Blue Card framework), or have equivalent specialised competences. Generic or low-skill roles are excluded.

Eligible Income

The regime applies to Italian-source employment income and self-employment income from arts and professions, including directors’ fees for duties performed in Italy. Business income from sole traders and partnerships, as well as passive income such as dividends, interest, capital gains and rental income, is not eligible and is taxed under the ordinary rules.

Benefits and Duration

The standard benefit is a 50 percent exemption of eligible income from IRPEF: only half is subject to Italian progressive income tax, and the same reduced base also applies to regional and municipal surtaxes. The exemption increases to 60 percent if the worker has a minor dependent child at the time of transfer or becomes a parent during the benefit period, provided the child resides in Italy.

The regime is capped at 600,000 euro of eligible income per year; any excess is fully taxed at ordinary rates. The duration is five tax years, starting from the year of transfer. Unlike the previous version, no extensions are available, not even where children or real estate purchases previously triggered a five-year extension.

Practical Points Before the Move

Eligibility turns on documentation. Returning Italian nationals must formally cancel their AIRE registration; foreign nationals must complete anagraphic registration with the Italian municipality. A codice fiscale is required, as is evidence of foreign residence during the look-back period — foreign tax returns, contracts, utility bills, AIRE certificates. Employees then submit a written request to the Italian employer, who applies the reduced withholding on monthly payroll; self-employed professionals apply the reduction directly in the annual tax return.

Common pitfalls include missing the 183-day test because of frequent remote working abroad, miscalculating the extended six- or seven-year look-back for those staying with the same group, and failing to document the high qualification requirement, which the Italian Revenue Agency is increasingly auditing. The regime is not combinable with the forfettario flat-tax regime, the 7 percent retiree regime for Southern Italy, or the lump-sum flat tax for new residents.

A Note for U.S. Citizens

U.S. citizens and green card holders continue to be taxed by the United States on worldwide income regardless of residence, and must keep filing Form 1040, FBAR and, where applicable, Form 8938. Because the Italian exemption reduces the Italian tax paid, the Foreign Tax Credit available to offset U.S. liability is lower, and residual U.S. tax may actually increase. The Italy–U.S. treaty’s saving clause preserves U.S. taxing rights over its citizens, so treaty relief is limited. Italian mutual funds and certain insurance wrappers are typically classified as PFICs and trigger punitive U.S. taxation and heavy reporting, and Italian complementary pensions may not qualify as tax-favoured plans under U.S. rules. A coordinated U.S./Italy projection before relocating is essential to model FTC, FEIE, state tax exit, and investment restructuring options.

Final Considerations

The 2026 Impatriati Regime remains a powerful incentive, but it rewards careful planning. Residence timing, documentation, the high qualification test and the interaction with other regimes can materially change the net benefit — and for U.S. persons the analysis must always be run on both sides of the Atlantic. Professional advice before the move is strongly recommended.

Italy’s 2026 Short-Term Rental Reform: Three-Property Threshold, CIN Enforcement, and EU Platform Reporting

Italy has restructured the tax and regulatory framework for short-term rentals from 1 January 2026, with a second wave of changes arriving in May 2026 under EU Regulation 2024/1028. The combined effect is a tighter environment for anyone letting a property for stays under 30 days — and a particularly important moment for international owners who rely on platforms such as Airbnb, Booking.com and Vrbo to reach guests.

The three-property threshold

The 2026 Budget Law has lowered the threshold at which short-term rental activity is classified as a business from five properties to three. Owning or managing three or more properties used exclusively for lettings of less than 30 days now triggers mandatory VAT registration, opening of a Partita IVA, social security contributions to INPS, and full business accounting.

This is a significant change. Small foreign investors who built a portfolio of three or four Italian apartments for vacation rental — a very common profile among international buyers — are automatically reclassified as businesses from this year, even if they previously enjoyed the straightforward cedolare secca treatment.

Cedolare secca: what stays and what changes

For non-professional hosts (one or two properties), cedolare secca remains available. The rate is 21% on the first property and 26% on each additional property, applied on gross rental income in lieu of IRPEF and local surtaxes. A proposal during the 2026 Budget Law debate to raise the first-property rate to 26% was dropped, so the pre-2026 structure has survived for the smallest landlords.

Owners above three properties lose access to cedolare secca entirely. Rental income falls into ordinary business taxation, subject to IRPEF on progressive brackets, IRAP in certain cases, and VAT where the activity takes on a hotel-like character (breakfast, cleaning between guests, reception desk).

CIN and the end of anonymous listings

Every property offered for short-term tourist use must now display a CIN (Codice Identificativo Nazionale) issued by the national accommodation database. Platforms are required to verify CIN compliance and delist properties without one. Fines for CIN violations range from €800 to €8,000 per property. Over 620,000 CINs were issued in the first year of operation — an indicator of just how actively the authorities are enforcing the new regime.

May 2026: EU platform reporting kicks in

From 20 May 2026, EU Regulation 2024/1028 requires platforms to transmit booking data directly to national authorities on a monthly basis. Owner identity, property address, number of nights booked, and amounts received will all flow automatically to the tax authorities. Foreign owners who, under previous opacity, were informally relying on platform payouts to a foreign bank account should assume that this data is now visible to the Agenzia delle Entrate in real time — and that any mismatch between declared income and reported bookings will be pursued.

Practical points for international owners

Anyone holding two properties and considering a third should run the numbers carefully — the tax, accounting and social-security burden of crossing the business threshold can easily outweigh the marginal return on a single extra unit. A different corporate structure (such as an Italian SRL) may work better at scale, but brings its own regime and compliance costs. For owners already at or above three properties, the priority is proper VAT registration and bookkeeping from day one of 2026 — corrective filings later in the year are possible but expensive.

A Note for U.S. Citizens

U.S. citizens remain taxable on worldwide rental income regardless of Italian residency status. Italian tax paid under cedolare secca or IRPEF is generally creditable in the United States via the Foreign Tax Credit, but cedolare secca’s flat structure sometimes produces mismatches with U.S. Schedule E mechanics, where expenses are normally deductible against gross rent. Properties held through Italian companies, or bank accounts used to receive rental payouts, can also trigger FBAR, FATCA, and in some cases PFIC reporting. These layers should be planned together before any scaling of Italian rental activity.

Final Considerations

The 2026 reform does not make short-term rental unattractive in Italy, but it ends the informal era. Owners who cross the three-property threshold, owners approaching it, and owners of even a single property without a CIN all face concrete compliance steps this year. Professional advice is strongly recommended before restructuring or expanding a portfolio.

Impatriati Regime and Minor Children: Why Families Moving to Italy Can Now Access the 60% Exemption More Easily

A recent clarification from the Italian Revenue Agency has expanded how the impatriati regime interacts with one of its most attractive features: the enhanced exemption for taxpayers with minor children. Response No. 82 of March 20, 2026 addressed a practical question that had been troubling international families and their advisors — whether the enhanced benefit applies when the children are already tax resident in Italy before the parent actually returns. The answer is yes, with significant consequences for planning a family relocation.

The current inbound workers regime, set out in Legislative Decree 209/2023, reduces the taxable base on Italian-source employment and self-employment income. The standard benefit cuts the taxable portion to 50% of income produced in Italy, applied for five tax years and capped at a maximum eligible income of €600,000 per year. For a worker returning under qualifying conditions, this halves the IRPEF burden on Italian earnings for half a decade, which is why the regime has become central to relocation planning for international professionals.

The Enhanced Benefit for Families

Where the taxpayer has at least one minor child who is tax resident in Italy, the taxable base falls further, from 50% to 40%. In practical terms, this means 60% of Italian-source income is exempt from IRPEF instead of 50%. The enhanced benefit is also triggered by the birth or adoption of a child during the five-year incentive window — in which case the improved treatment applies from the tax period in which the event occurs and continues for the remaining eligible years.

The benefit requires the child to be tax resident in Italy, and that residence must be maintained throughout the benefit period. If the child later leaves Italy, the enhanced treatment ceases from the year in which that condition is no longer satisfied.

t requires the child to be tax resident in Italy, and that residence must be maintained throughout the benefit period. If the child later leaves Italy, the enhanced treatment ceases from the year in which that condition is no longer satisfied.

What the March 2026 Clarification Adds

The key point in Response No. 82/2026 is the timing of the child’s residence. The Revenue Agency confirmed that it is not necessary for the child’s transfer to Italy to coincide with, or follow, the parent’s relocation. A minor child who was already resident in Italy before the incoming worker actually qualifies as a resident triggers the enhanced benefit, provided Italian residence is preserved for the duration of the regime.

This matters in real-life patterns the firm sees often: a parent who spent recent years working abroad while the family remained in Italy; a couple where one spouse relocated ahead of the other with the children; or international families who sent children to Italian schools before committing to a full household move. Under the previous reading, some practitioners were cautious about claiming the enhanced 60% exemption in these scenarios. The 2026 clarification removes that uncertainty.

The same ruling reaffirms a second important point: the regime is compatible with smart working for a foreign employer. A worker who returns to Italy while continuing the same employment relationship with a non-Italian company may still qualify, provided the activity is performed predominantly from Italian territory and the other statutory conditions — including the foreign residence requirement prior to transfer — are satisfied.

A Note for U.S. Citizens

Because the United States taxes its citizens on worldwide income regardless of residence, a U.S. citizen benefiting from the Italian impatriati regime still files a U.S. return. The enhanced 60% Italian exemption means a smaller amount of Italian tax is paid on the same gross Italian income, which in turn reduces the Foreign Tax Credit available on the U.S. return. The practical result is that the Italian saving can translate into a higher residual U.S. liability rather than a straightforward net reduction in total tax. FBAR and FATCA obligations remain unchanged. A coordinated U.S.–Italy projection is essential before assuming the headline benefit will flow through to cash savings.

Final Considerations

The impatriati regime is one of the most powerful tools Italy offers to international workers, and the enhanced rate for families makes it particularly relevant to households planning a long-term move. The March 2026 clarification opens the door to a broader set of scenarios, but the rules on tax residence, timing of the transfer, and the child’s continued Italian residence leave no room for improvisation. Anyone considering a move — or already inside the five-year window — should have the family’s situation reviewed before filing decisions are locked in.

Selling Into Italy From Abroad: The July 2026 Customs Shake-Up for Low-Value Parcels

On 1 July 2026 two separate but overlapping reforms will change the cost structure of shipping low-value goods into Italy from outside the European Union. The EU will introduce a flat €3 customs duty on every item in parcels valued up to €150 sent to consumers, and Italy will simultaneously raise its own handling fee from €2 to €3 per parcel to align with the EU measure. For any foreign company that relies on direct-to-consumer shipping into the Italian market — US, UK, Swiss or Asian sellers especially — the break-even maths changes materially, and the window to restructure is short.

The Italian fee has actually been in place since 1 January 2026. It applies to non-EU low-value consignments cleared through Italian customs, regardless of the declared value of the goods. It is charged per parcel, not per item, and is collected by the customs clearance agent from the importer of record — in most B2C cross-border sales, that is the end consumer. The increase to €3 scheduled for 1 July 2026 is not a new fee but an adjustment of the existing charge so that the Italian administrative cost matches the new EU duty.

The EU-level reform is more disruptive. The flat €3 customs duty is an interim measure, introduced ahead of the full abolition of the €150 de minimis exemption expected in 2028. Unlike the Italian handling charge, the €3 duty is assessed per item and is based on the tariff classification of the goods. A single parcel containing three distinct SKUs with different tariff headings will therefore attract €9 in customs duty, before VAT and before Italy’s €3 handling fee.

Who absorbs the cost

In a standard non-EU B2C shipment using IOSS (Import One Stop Shop), VAT is pre-collected at the point of sale by the seller. IOSS continues to work under the new rules for the VAT piece, but the customs duty and the handling fee are in addition. Sellers outside the EU have three practical choices. They can pass the combined cost (up to €6 per parcel, plus duty-per-item) on to the Italian consumer at checkout, which is transparent but damages price competitiveness. They can absorb it into the sale price, which compresses margins. Or they can restructure the supply chain — holding stock inside the EU, shipping business-to-business into an EU warehouse, and fulfilling the Italian consumer from within the single market, which removes the import event entirely.

Routing alternatives are narrower than they appear

Because Italy’s handling fee is triggered only when goods are physically cleared at an Italian customs office, it is possible in theory to route shipments through another EU entry point (for example Germany or the Netherlands) and transit them to Italy under intra-EU movement rules. In practice, other Member States are introducing their own handling charges aligned to the EU reform, so the arbitrage window is closing. Foreign sellers should model the total landed cost country by country rather than assuming a single optimised route.

A Note for U.S. Citizens

For U.S.-based sellers shipping directly to Italian consumers, the practical impact is immediate: the Section 321 de minimis logic that allows low-value shipments into the U.S. duty-free has no EU analogue from July 2026. Any seller currently operating on the assumption that parcels under €150 reach Italy duty-free should update their checkout flow and customer communications before the July deadline. U.S. sellers should also verify that their IOSS intermediary is ready to collect the flat €3 duty alongside VAT; if not, duty becomes payable on arrival and parcels may be held pending payment.

Final Considerations

The July 2026 reforms are not about revenue — the EU is aligning its treatment of low-value imports with the reality that the €150 threshold has become a compliance loophole. For foreign sellers the strategic question is no longer “how do I minimise per-parcel friction?” but “where should my European stock actually sit?” Sellers with meaningful Italian volume should evaluate a warehouse inside the EU, IOSS readiness, and tariff-classification discipline well before the deadline. Each of these choices has VAT, customs, and permanent-establishment implications that need to be modelled together, not in isolation.

Foreign companies selling into Italy are encouraged to review their customs and VAT position with qualified advisers before the July 2026 changes take effect.

Italy’s Avviso Bonario: What It Is and What to Do When You Receive One

An avviso bonario is a preliminary notice issued by the Italian Revenue Agency (Agenzia delle Entrate) when automated or formal checks of a tax return reveal possible irregularities. It is not yet a formal assessment and not yet a tax bill — it is an invitation to either pay what the Agency believes is due, or demonstrate why the Agency is wrong, at substantially reduced penalties. For foreign residents and international businesses operating in Italy, handling it correctly is essential: ignoring the notice almost always leads to enforcement action at a much higher cost.

When and How It Arrives

The avviso bonario is generated after one of two types of control performed on a return already filed:

The automated check (controllo automatizzato), under Article 36-bis of Presidential Decree 600/1973 for direct taxes and Article 54-bis of Presidential Decree 633/1972 for VAT, is a computerised matching between what was declared and what was actually paid or withheld.

The formal check (controllo formale), under Article 36-ter, is a deeper review where the Agency verifies supporting documentation for deductions, tax credits, withholdings and other specific items on the return.

The notice usually arrives two to three years after the return was filed. For taxpayers who filed independently, it is delivered by registered post or made available in the taxpayer’s online tax account (cassetto fiscale). For those who filed through an accountant or a CAF, the notice is transmitted electronically via the Entratel channel directly to the intermediary, who is expected to forward it promptly.

Which Taxes and Contributions Are Covered

Avvisi bonari can concern virtually every tax or contribution managed through the Italian tax return: IRPEF and IRES (personal and corporate income tax), IRAP, VAT, cedolare secca on rental income, IVIE and IVAFE on foreign real estate and financial assets, regional and municipal surcharges, substitute taxes on investment income, and withholding taxes. They also cover INPS social security contributions reported through the tax return, which is particularly relevant for self-employed professionals and holders of a partita IVA.

Payment Terms and Reduced Penalties

The key advantage of resolving an avviso bonario is a significant reduction of the statutory penalty.

For automated checks, the penalty is reduced to one-third of the ordinary amount. For formal checks, the reduction is to two-thirds. Following the 2024 reform of the Italian penalty system, the base penalty for omitted or insufficient payment is 25 percent for violations committed from 1 September 2024 onwards (it was 30 percent before that date). In practice, the effective penalty after reduction is approximately 8.3 percent for automated controls and 16.7 percent for formal ones, plus interest accrued from the original deadline to the date of payment.

To benefit from the reduction, the taxpayer must pay within 30 days from receipt of the notice. When the notice is routed through a tax intermediary, the effective deadline is 90 days from the Agency’s transmission date.

Since January 2025, installment plans have been standardised: up to 20 quarterly installments are now available regardless of the amount due. Missing the first installment — or any two later ones in a row — causes the entire balance to become immediately payable with full penalties.

What to Do If You Receive One

The first step is to check whether the figures are correct. Common triggers include F24 payments not properly matched to the return, missing or misreported withholdings, documentation not transmitted by third parties (for example, medical expenses or mortgage interest), and double-counting of tax credits.

If the notice is correct, payment is made with the pre-filled F24 form attached to the communication, or through an installment request submitted via the taxpayer’s online account.

If the notice contains errors, the taxpayer or their advisor can file a CIVIS request — an online service dedicated to the review of avvisi bonari — attaching documentation that supports the original return. The 30-day payment deadline is not automatically suspended, so the request should be filed immediately. In the majority of cases, a well-documented CIVIS submission leads to full or partial cancellation of the notice.

Ignoring the avviso bonario is the worst possible option. After the deadline, the sum is referred to Agenzia delle Entrate Riscossione, and a formal cartella di pagamento is issued with full penalties, statutory interest and collection fees. At that point, the reduced-penalty benefit is permanently lost, and recovery may include wage or bank account attachments.

A Note for U.S. Citizens and Other Foreign Taxpayers

Expats frequently receive avvisi bonari because of mismatches in the reporting of foreign income, foreign tax credits, or assets held abroad (quadro RW). Before paying, it is always worth checking whether the underlying issue is a genuine additional liability or a reporting mismatch that can be corrected. In many cross-border situations, the notice can be cancelled by producing evidence of foreign withholding tax actually paid or of treaty-based relief. U.S. citizens should be especially careful: an Italian adjustment can change the Foreign Tax Credit position on Form 1116, and any correction on the Italian side may require a corresponding amendment in the U.S. return to preserve the credit.

Final Considerations

An avviso bonario is not yet a legal dispute — it is the final opportunity to resolve a tax position at a reduced cost and without litigation. The 30-day window is short, but it is almost always enough either to pay, to request installments, or to challenge the figures through CIVIS. Given the cross-border complexity that typically affects expats and foreign companies in Italy, the most effective course of action is to involve a qualified Italian tax professional as soon as the notice is received — well before the deadline, rather than after.

Italy’s Digital Nomad Visa: What Remote Workers Need to Know About Tax and Social Security

Italy formally launched its Digital Nomad Visa under Legislative Decree 4/2022, and in early March 2026 the government published long-awaited implementing guidelines that clarify who qualifies, what documentation is required, and — crucially — how Italian tax and social security rules apply. If you are working remotely for a client or employer based outside Italy and considering a move, understanding the tax framework is at least as important as securing the visa itself.

Who the Visa Is For

The framework distinguishes between two categories of applicant. Self-employed digital nomads are freelancers or sole traders who provide services to clients outside Italy. Remote workers are employees of a foreign company who carry out their duties entirely from Italy. Both categories require an initial residence permit valid for up to one year, renewable, but the documentation and compliance obligations differ.

To qualify, applicants must demonstrate a minimum annual income of approximately €28,000 — some consulates apply a stricter threshold in practice — along with private health insurance covering at least €30,000, a confirmed rental contract or property deed, and evidence of at least six months of relevant professional experience. Family members (spouse and dependent children) receive co-terminous residence permits and gain access to Italy’s national health service once the principal permit is issued.

How Italian Tax Works for Digital Nomads

Contrary to what some online guides suggest, Italy does not have a dedicated tax regime for digital nomad visa holders. Ordinary Italian tax rules apply from the moment you become an Italian tax resident — which occurs once you spend more than 183 days in Italy in a calendar year, register at the municipal registry office, or establish your habitual abode in Italy.

For self-employed digital nomads, the most immediately useful structure is the flat-rate regime (regime forfettario). Eligible freelancers pay a substitutive tax of 5% on a deemed percentage of gross revenues for the first five years, rising to 15% thereafter, provided annual income does not exceed €85,000. Compliance is significantly simplified, as there is no VAT to charge clients abroad and accounting requirements are minimal.

Employees or those who do not qualify for the flat-rate regime are subject to ordinary progressive income tax (IRPEF) at rates up to 43%. Some remote workers who relocate to Italy may separately qualify for the inbound workers regime (regime impatriati), which exempts 50% of qualifying employment or professional income from IRPEF for five years. However, this regime has its own eligibility conditions — including prior foreign residence of at least two of the previous three years, a commitment to remain in Italy for at least four years, and a qualification or specialisation requirement — and it must be applied for separately. Holding the digital nomad visa does not automatically confer access to it.

Social Security: A Frequently Overlooked Obligation

Self-employed visa holders must register with INPS and pay contributions to the Gestione Separata (separate social security fund) at a rate of approximately 26% on net taxable income. This adds substantially to the cost of working in Italy as a freelancer and is often underestimated at the planning stage.

For employees of foreign companies, the applicable social security framework depends on whether Italy has a totalization agreement with the employer’s home country. Where such an agreement exists — as it does with the United States — contributions may remain payable in the home country rather than in Italy for a defined period.

The Permanent Establishment Risk for Employers

One of the most significant tax risks of the digital nomad framework does not fall on the individual at all: it falls on the foreign employer. When an employee works from Italy continuously and at the employer’s direction, Italian tax authorities may classify the worker’s home office as a fixed place of business — creating a permanent establishment of the foreign company in Italy and exposing the employer’s profits to Italian corporate tax. This risk is particularly acute for employees who set up Italian tax residency on a long-term basis. Foreign employers with staff relocating under the digital nomad visa should assess their permanent establishment exposure before approving the arrangement.

A Note for U.S. Citizens

U.S. citizens are taxed by the United States on their worldwide income regardless of where they live, so moving to Italy does not eliminate the U.S. filing obligation. Italy and the United States have a double tax treaty, and Italian taxes paid on income also subject to U.S. tax are generally creditable against U.S. federal tax via the Foreign Tax Credit (Form 1116). However, the flat-rate regime (forfettario) presents a complication: because it operates as a substitutive tax rather than a standard income tax, the IRS may not treat it as a creditable foreign income tax, meaning forfettario users could face both Italian and U.S. tax on the same income without full offset. This point deserves specific analysis before choosing the forfettario option. FBAR and FATCA reporting obligations for Italian financial accounts also continue to apply regardless of which Italian tax regime is chosen.

Final Considerations

Italy’s Digital Nomad Visa gives remote workers a clear legal pathway to live and work in Italy that did not exist before. The tax picture is more complex than the visa rules alone suggest: choosing the right Italian tax structure, understanding the social security obligations, assessing the permanent establishment risk to your employer, and managing any home-country obligations simultaneously all require careful planning. The interaction between the digital nomad visa and Italy’s various incentive regimes is an evolving area, and proposed changes to the Budget Law could alter the landscape further in the near term. Professional advice tailored to your specific situation — covering both Italian and home-country tax — is essential before making the move.

Italy’s Inheritance and Gift Tax Reform: What International Families Need to Know

Italy’s Inheritance and Gift Tax Reform: What International Families Need to Know

Italy has overhauled its rules on inheritance and gift taxation through two legislative decrees — Decree 139/2024 and Decree 123/2025 — with the most significant changes taking effect on January 1, 2026. For expats, foreign nationals with property in Italy, and international families with cross-border estate plans, the reform introduces both meaningful opportunities and new compliance obligations.
Tax Rates Are Unchanged — But the Thresholds Just Got Better
Italy’s headline inheritance and gift tax rates remain the same: 4% for transfers to spouses and direct descendants (children, grandchildren), 6% for siblings and other relatives up to the fourth degree, and 8% for unrelated beneficiaries. What changed is how the tax-free threshold — called the franchigia — is calculated.
Under the old system, a mechanism known as the coacervo required the tax authority to aggregate all lifetime gifts made to a beneficiary with whatever they ultimately received through inheritance. A child who received a €600,000 gift from a parent during their lifetime had only €400,000 of their €1 million threshold left when the parent died. This aggregation rule, abolished as of January 1, 2026, had long been criticised as penalising families who used gifting as part of their estate plan.
From 2026 onward, gifts and inheritances each carry their own separate €1 million threshold per qualifying beneficiary (spouse or direct descendant). A child can now receive up to €1 million in lifetime gifts and still benefit from a full €1 million threshold upon inheritance. For siblings, the separate thresholds stand at €100,000 each. In practical terms, this change doubles the potential tax-free transfer capacity between generations for families who use both instruments.
Trusts: Now Expressly Addressed in Italian Succession Law
For the first time, Italy’s succession tax legislation expressly addresses the treatment of trusts. Previously, the framework had developed through administrative circulars and case law, leaving considerable uncertainty for international structures.
The new rules confirm that transfers of assets via trust are subject to inheritance and gift tax whenever they result in a gratuitous enrichment of beneficiaries. Crucially, the reform gives trustees and settlors a planning choice: they may elect to trigger the tax at the time assets are contributed to the trust, or defer it until assets are distributed to beneficiaries. Where beneficiaries are not yet identified, the 8% rate — applicable to transfers between strangers — applies by default. Once the tax is paid at either stage, subsequent distributions in the same kinship category are not taxed again.
The territorial rules for trust taxation follow the settlor’s residency at the time assets are contributed to the trust, not at distribution. If the settlor was an Italian tax resident when the assets entered the trust, Italian succession tax applies to all transferred assets, wherever located. Non-resident settlors face Italian tax only on Italian-sited assets.
Self-Assessment Is Now the Taxpayer’s Responsibility
Another structural change affects how the tax is collected. Under the previous system, the Agenzia delle Entrate calculated the tax owed and issued a formal notice. The reform shifts this obligation to the taxpayer: heirs and beneficiaries must now calculate, declare, and pay the inheritance tax themselves, within 90 days of the succession opening. The tax authority retains a two-year window to challenge the calculation. Electronic filing is required in most cases, though non-resident heirs may still submit declarations by registered mail.
This change increases the importance of getting professional advice promptly after a death, since errors in self-assessment can lead to penalties.
Cross-Border Estates: Who Is Taxed on What
Italy’s territorial scope for inheritance tax follows the residence of the deceased at the time of death, not the location of the assets. If an Italian tax resident dies, their worldwide estate — including foreign bank accounts, foreign real estate, and financial investments held abroad — is subject to Italian succession tax. Conversely, if a non-resident dies but owned property in Italy, only the Italian assets are within scope. Beneficiaries who are themselves Italian residents must report and pay tax on all assets received from an Italian-resident decedent, regardless of where those assets are physically located.
There is no bilateral inheritance or estate tax treaty between Italy and most countries, including the United States. Families with assets in multiple jurisdictions should model the combined tax exposure carefully.
A Note for U.S. Citizens
U.S. citizens are subject to U.S. federal estate and gift tax on their worldwide assets, regardless of where they live. Unlike the Italy-U.S. income tax treaty, there is no Italy-U.S. estate and gift tax treaty. This means a U.S. citizen who is an Italian tax resident may face both Italian inheritance/gift tax and U.S. estate or gift tax on the same transfer, with limited mechanisms to avoid double taxation.
Italy’s rates — 4% to 8% — are substantially lower than the U.S. federal estate tax rate of 40% on amounts above the exemption. The U.S. does provide a foreign death tax credit under Section 2014 of the Internal Revenue Code for foreign estate taxes paid on assets that are also subject to U.S. estate tax, but this credit has specific limitations and does not always provide full relief. For gifts, the interaction is more complex: Italy now taxes certain gift transactions that the U.S. would treat as taxable gifts, but the tax systems operate independently.
U.S. citizens in Italy who hold assets in trust structures — particularly grantor trusts used in U.S. estate planning — should review how the new Italian trust taxation rules interact with their existing structures.
Final Considerations
The 2026 reform makes Italy’s succession tax framework more transparent and, for many families, more generous in terms of available exemptions. The abolition of the coacervo is a genuine planning improvement. At the same time, the shift to self-assessment raises the stakes for accurate compliance, and the new trust rules introduce mandatory analysis for anyone with a trust structure linked to Italy.
For international families — particularly those with assets, heirs, or residency ties in multiple countries — the practical impact of these changes depends heavily on individual circumstances. Professional advice is recommended before making gifts, establishing trusts, or updating cross-border estate plans in light of the new framework.

Italy’s 2026 Crypto Tax: What the 33% Rate Means for Residents and Expats

Italy’s 2026 Crypto Tax: What the 33% Rate Means for Residents and Expats

Italy’s approach to taxing digital assets has shifted decisively with the 2026 Budget Law. The changes are significant enough that anyone living in Italy who holds cryptocurrency — or who is considering moving to Italy and has crypto holdings — needs to understand the new rules before the current tax year produces taxable events.

The New 33% Capital Gains Rate

From January 1, 2026, capital gains on most crypto-assets — including Bitcoin, Ether, and dollar-denominated stablecoins such as USDT and USDC — are subject to a 26% substitute tax that was already in place since 2023. That rate has now been raised to 33%. The increase was introduced by the 2026 Budget Law and applies to all disposal events: selling crypto for euros or other fiat currency, swapping one crypto for another, and using crypto to pay for goods or services.

The 33% rate aligns crypto gains more closely with the tax treatment of other speculative financial income under Italian law, a clear signal of the government’s intention to treat digital assets as a permanent and fully taxed asset class.

The €2,000 Threshold Is Gone

Until the end of fiscal year 2024, Italian tax residents could realize crypto gains of up to €2,000 per year without owing tax. That exemption was abolished from fiscal year 2025 onward. It does not return in 2026. Every euro of realized gain is now taxable, regardless of how small the transaction.

For occasional holders who previously relied on staying below the threshold, this change demands attention even for modest portfolio activity.

Euro Stablecoins: A Lower Rate

The 2026 Budget Law creates a specific carve-out for electronic money tokens (EMTs) — digital instruments that maintain a fixed parity with the euro and are issued under the EU’s MiCAR regulation. These include euro-denominated stablecoins such as EURC and EURS. Capital gains on these instruments are taxed at 26% rather than 33%, a meaningful difference for traders who regularly move between volatile assets and stable reserves.

Dollar-pegged stablecoins do not qualify. The preferential rate is limited to euro-denominated tokens that meet MiCAR’s reserve and licensing requirements.

The 18% Redetermination Option

The Budget Law also offers a one-time option to redetermine the cost basis of crypto holdings as of January 1, 2026 by paying an 18% substitute tax on the portfolio’s value at that date. This effectively resets the acquisition cost to the current market value, reducing the taxable gain on any future sale. For long-term holders sitting on large unrealized gains, this can substantially reduce the effective tax burden when they eventually sell — though it requires paying the 18% charge upfront.

The decision of whether to exercise this option requires calculating the likely future gain against the immediate cost, and it is most attractive when the existing cost basis is very low relative to current value.

Reporting: Quadro RW and Quadro RT

Italian tax residents must report foreign-held crypto assets in Quadro RW of the Redditi PF return. This form is used both for monitoring purposes and, in many cases, for calculating the IVAFE wealth tax on financial assets held abroad. The applicable IVAFE rate and whether it applies to crypto assets held on foreign platforms should be confirmed for each specific situation, as the rules in this area have been subject to revision. Where assets are held on Italian-licensed platforms, reporting requirements may differ.

Quadro RT is used to declare capital gains and losses. Losses can be carried forward to offset gains in the following four tax years, provided they are declared in the year they arise.

Failure to complete either form carries substantial penalties: non-reporting of foreign assets can result in penalties of 3% to 15% of the undisclosed amount, in addition to fixed sanctions.

A Note for U.S. Citizens

On the U.S. reporting side, crypto held on foreign exchanges may qualify as a specified foreign financial asset under FATCA, requiring disclosure on Form 8938 if aggregate foreign financial assets exceed the applicable filing threshold ($50,000 for individuals filing a return in the United States). FBAR reporting for foreign crypto accounts remains a developing area: FinCEN has signaled its intention to extend FBAR requirements to foreign virtual asset accounts, and U.S. citizens should monitor this closely given proposed rules currently pending finalization.

The combination of Italian income tax, potential IVAFE on foreign-held assets, U.S. federal tax obligations, and parallel reporting requirements under both systems makes cryptocurrency one of the more complex compliance areas for U.S. nationals in Italy.

Final Considerations

The 2026 changes mark a clear shift toward treating crypto-assets as mainstream financial instruments under Italian law, with the rates and reporting requirements now reflecting that approach. The abolition of the €2,000 exemption and the increase to 33% mean that even moderate holders face meaningful tax obligations that did not exist under prior rules.

Anyone with Italian tax residency and crypto holdings should review their position, confirm their cost basis documentation, and evaluate whether the 18% redetermination option makes sense in their individual circumstances. The interaction between Italian and foreign tax obligations — particularly for U.S. citizens — adds further layers that are best addressed with professional advice before the end of the tax year.

Foreign Assets and Italian Tax Residency: A Practical Guide to Quadro RW, IVAFE, and IVIE

Foreign Assets and Italian Tax Residency: A Practical Guide to Quadro RW, IVAFE, and IVIE

Becoming an Italian tax resident does not only affect how your income is taxed — it also triggers a set of obligations relating to assets you continue to hold abroad. Anyone who transfers their tax residency to Italy and retains a foreign bank account, investment portfolio, property, or equity stake must comply with Italy’s foreign asset monitoring and wealth tax framework. Failing to do so carries significant penalties. This article provides a practical overview of what is required and what it costs.

The Monitoring Obligation: Quadro RW

Every Italian tax resident who holds financial or non-financial assets outside Italy at any point during the tax year must disclose them in Quadro RW, a dedicated section of the Italian personal income tax return. The purpose is twofold: it gives the tax authorities visibility over assets held offshore, and it serves as the basis for calculating the two wealth taxes described below.

Assets subject to disclosure include foreign bank and deposit accounts, brokerage accounts, stocks and bonds held outside Italy, shares in foreign companies, investment funds domiciled abroad, foreign real estate, foreign pension accounts, cryptocurrencies held on foreign platforms, and precious metals or valuables kept outside Italian territory. The list is broad, and the Italian Revenue Agency interprets it expansively.

The reporting threshold for foreign bank accounts is an average annual balance exceeding €5,000. In practice, however, any account that at any point during the year exceeds a daily balance of €15,000 must also be reported for monitoring purposes, even if the average stays below the threshold. For all other financial assets — securities, funds, equity interests — there is no minimum threshold: they must be reported regardless of value.

Until recently, Quadro RW was only available in the longer Redditi PF form, which many employed workers were not required to file. From the 2024 tax period onward, the equivalent section — Quadro W — has been incorporated into the simplified 730 form, making compliance accessible to a broader group of taxpayers, including employees and pensioners.

IVAFE: Wealth Tax on Foreign Financial Assets

IVAFE (Imposta sul Valore delle Attività Finanziarie Estere) is an annual wealth tax levied on financial assets held abroad. The standard rate is 0.2% per year, applied to the market value of the assets as at 31 December of the relevant tax year, or the average value where no year-end market price is available.

For foreign current and savings accounts, the tax is calculated differently: a flat charge of €34.20 per account per year applies, rather than a percentage. IVAFE on bank accounts is not due if the average annual balance does not exceed €5,000.

Assets held in or through jurisdictions on Italy’s list of non-cooperative tax territories are subject to a higher rate of 0.4% — double the standard charge. This applies where the financial intermediary or the asset itself is located in a blacklisted country.

IVAFE is calculated and paid through the annual tax return. A credit is available for any similar wealth taxes paid to a foreign government on the same assets, avoiding outright double taxation — though the mechanics of the credit vary depending on the country and the nature of the asset.

IVIE: Wealth Tax on Foreign Real Estate

IVIE (Imposta sul Valore degli Immobili situati all’Estero) is the equivalent charge applied to real estate owned outside Italy. Since the 2024 tax year, the rate has been 1.06% per year, following an increase from the previous 0.76% introduced by the 2024 Budget Law.

The taxable base is generally the purchase price of the property, or its cadastral value if available in the relevant foreign country. Where neither is available, the market value at the relevant date is used. A reduced rate of 0.40% applies to property used as the taxpayer’s principal residence abroad, with a €200 deduction.

As with IVAFE, a credit is available for property taxes paid in the country where the real estate is located, which in many cases eliminates or substantially reduces the Italian charge.

Penalties for Non-Compliance

The consequences of failing to file Quadro RW are material. For assets held in EU or EEA countries, the penalty ranges from 3% to 15% of the undisclosed asset value. For assets held in non-EU countries, the range rises to 6% to 30%. Where the country involved is on Italy’s list of non-cooperative jurisdictions, penalties are doubled again. In addition, the statute of limitations for undisclosed foreign assets is extended beyond the ordinary term, giving the Revenue Agency more time to raise assessments.

A Note for U.S. Citizens

U.S. citizens living in Italy face a parallel disclosure system on top of the Italian obligations. FBAR (FinCEN Form 114) requires reporting any foreign financial account to the U.S. Treasury if the aggregate value of all foreign accounts exceeds $10,000 at any point during the calendar year. Form 8938 (FATCA) requires disclosure of specified foreign financial assets above thresholds that vary by filing status and residency. Both obligations exist independently of Quadro RW — the same accounts and assets may need to be reported in all three filings. The Italian and U.S. systems do not exchange information automatically in a way that substitutes for compliance on either side.

Final Considerations

For anyone who has recently moved to Italy and retains assets abroad — whether a bank account in their home country, a brokerage account, a pension fund, or a property — the RW obligation applies from the first year of Italian tax residency. The interaction between IVAFE, IVIE, and any foreign wealth taxes already paid requires careful calculation. Professional advice is strongly recommended before filing, particularly for complex asset structures or assets held in non-EU jurisdictions.

Impatriati Regime: Moving from Southern to Northern Italy Has Retroactive Tax Consequences

Impatriati Regime: Moving from Southern to Northern Italy Has Retroactive Tax Consequences

Italy’s inbound workers tax regime (regime degli impatriati) offers significant income tax relief to professionals and employees who transfer their residency to Italy after a qualifying period abroad. For those who settle in one of Italy’s southern regions, the benefit is even greater — but a ruling issued by the Italian Revenue Agency in March 2026 makes clear that relocating north mid-way through the relief period comes at a cost, and that cost runs backwards in time.

The Enhanced Benefit for Southern Regions

Under the rules applicable to workers who returned to Italy before 2024, the standard impatriati regime exempts 70% of qualifying income from IRPEF — meaning only 30% is subject to ordinary income taxation. For workers who transfer their residency to one of eight specified southern regions (Abruzzo, Molise, Campania, Puglia, Basilicata, Calabria, Sardinia, and Sicily), the exemption rises to 90%, with only 10% of qualifying income taxed. This enhanced relief was designed not just to attract workers to Italy, but to channel them specifically into regions where the economy needs a boost.

The legislation conditions this 90% rate on one key requirement: the worker must maintain residency in the qualifying southern region for the entire five-year duration of the benefit. What happens if they don’t was, until recently, less clear in practice.

What Ruling 76/2026 Decides

The case underlying the ruling involved a professional who returned to Italy in 2023 and established residency in Puglia, applying the 90% exemption from the outset. In 2024 they began a new employment with a Rome-based employer, and in 2025 they transferred their registered residency to Lazio. They asked the Revenue Agency three questions: does the move end all impatriati benefits, when exactly does the change take effect, and must prior years be corrected?

The Agency’s answer, issued on 11 March 2026, addresses all three points.

On the first question, the news is positive: moving to a non-qualifying region does not terminate the entire impatriati regime. The worker retains the standard 70% exemption for the remaining years of their five-year window. Only the enhanced 90% tier is lost.

On the second and third questions, the answer is considerably harsher. The Agency holds that the loss of the 90% benefit does not operate only from the date of the move, nor only for future tax years. It applies retroactively from the very first year of Italian residency. The reasoning is that the enhanced rate was never truly earned: the legislation requires uninterrupted southern residency throughout the entire benefit period, and since that condition was not ultimately met, the taxpayer never had the right to the 90% rate in the first place.

The Practical Consequence: Amending Prior Returns

For the worker in the ruling, this means the 90% rate applied to 2023 — the year of return, when they genuinely lived in Puglia — must be unwound. An amended tax return (dichiarazione integrativa) is required for that year, recalculating taxable income at the 30% standard level rather than the 10% enhanced level. The resulting additional tax, plus interest and penalties under Art. 1, comma 2, D.Lgs. 471/1997, must be paid. The voluntary disclosure mechanism (ravvedimento operoso) is available if the conditions are met, which can reduce the penalties.

The Agency adds a further, final point: a subsequent move back to a southern region would not restore the 90% exemption. What matters is continuous and unbroken residency in a qualifying region from the moment of first return. Once that continuity is broken, it cannot be reconstructed.

A Note for U.S. Citizens

U.S. citizens who applied the 90% exemption and claimed Italian taxes paid as a Foreign Tax Credit on their U.S. returns will need to consider the knock-on effect. Amending an Italian return to report higher taxable income and pay more Italian tax also means revisiting the U.S. returns for the relevant year — the FTC calculation will change. Depending on the amounts involved and whether the taxpayer was in an excess credit or excess limitation position, the U.S. tax impact could go in either direction. Professional advice covering both jurisdictions is essential before filing any amended return.

Final Considerations

Ruling 76/2026 draws a strict line: the enhanced southern-region benefit is all-or-nothing over the full five years. Workers who chose their Italian location partly with the 90% exemption in mind should treat any planned internal relocation as a tax event requiring prior analysis, not just a change of address. If a move north is under consideration, calculating the retroactive adjustment and the cost of regularising prior years before committing is strongly advisable. A specialist review at the planning stage is far less costly than correcting the position after the fact.

Working Remotely for a Foreign Employer? Italy’s Impatriati Regime Now Officially Applies

Working Remotely for a Foreign Employer? Italy’s Impatriati Regime Now Officially Applies

One of the most frequent questions we receive from professionals considering a move to Italy is whether the impatriati regime — Italy’s 50% income tax exemption for inbound workers — applies when their employer is based abroad and they plan to work from home in Italy. In January 2026, the Italian Revenue Agency answered that question clearly.

The Ruling: Location of Work, Not of Employer

The Revenue Agency confirmed that the impatriati regime is fully available to employees who transfer tax residence to Italy and continue working remotely for a foreign employer, provided the activity is carried out predominantly from Italian territory. The principle is straightforward: what counts is where the work is actually performed, not where the employer is located. If you live and work in Italy — even if your contract is governed by foreign law or your payslips come from a company headquartered abroad — you can claim the 50% IRPEF exemption on your qualifying income for five years. This applies to the new impatriati regime in force since 2024. Qualifying workers who transfer residence to Italy can exclude 50% of their Italian-source employment or self-employment income from IRPEF, up to €600,000 per year, for five consecutive tax years.

Key Requirements

Under the reformed regime, the worker must transfer Italian tax residence and not have been resident in Italy for at least the three years immediately preceding the transfer. A degree (bachelor level or equivalent) is required for highly qualified or specialised roles. Work must be performed predominantly in Italy, meaning more than 183 days per year physically working from Italian territory. Notably, the new regime no longer requires the old “functional link” between the transfer of residence and the start of the qualifying work activity — making it easier for workers who return to Italy independently of any job change.

A Note for U.S. Citizens

U.S. citizens are taxed by the United States on their worldwide income regardless of where they live. Moving to Italy and claiming the impatriati exemption does not reduce the U.S. tax bill directly. However, Italian income taxes paid should in principle generate Foreign Tax Credits against U.S. liability — though the precise mechanics depend on how the income is characterised and on the applicable treaty provisions. U.S. citizens in this situation should seek advice from a professional experienced in both Italian and U.S. taxation before assuming the credits will offset in full.

Practical Points

Remote workers should keep records to demonstrate they worked predominantly from Italian territory: diary entries, travel records, and any documentation from the employer confirming the remote arrangement. If the foreign employer does not apply Italian payroll withholding, the worker self-declares the income and the impatriati exemption in their Italian annual tax return — the Revenue Agency has confirmed this is the standard approach. One consideration for employers: if a senior employee habitually concludes contracts on behalf of a foreign company from Italian soil, that company could inadvertently create a taxable presence in Italy. This is a corporate structuring question the employer’s own advisers should evaluate.

Final Considerations

The ruling removes a practical ambiguity that had discouraged many remote professionals from claiming a benefit they were entitled to. For professionals already resident in Italy and working remotely for a foreign employer — or planning such a move — the five-year clock starts from the first year of Italian tax residence, so timing matters. As always, cross-border situations require coordinated advice. The Italian regime is generous, but it does not operate in isolation from a taxpayer’s home-country obligations.

Italy’s Non-Dom Flat Tax Just Got More Expensive: What the €300,000 Lump Sum Means for New Residents in 2026







Italy’s new-resident lump sum tax regime — one of the most generous non-domicile regimes in Europe — has become significantly more expensive for anyone moving to Italy from 1 January 2026. The country’s 2026 Budget Law raised the annual substitute tax from €200,000 to €300,000, and doubled the charge for qualifying family members from €25,000 to €50,000 each. For high-net-worth individuals considering a move to Italy, this change reshapes the planning calculus — though it does not eliminate the regime’s substantial advantages.

What the Regime Offers

Introduced in 2017 under Article 24-bis of the Italian Tax Code (TUIR), the regime allows individuals who have not been Italian tax residents for at least nine of the previous ten years to replace ordinary Italian taxation on all foreign-source income with a single annual lump-sum payment. That payment is now €300,000 per year, irrespective of how much foreign income was actually earned. A British executive receiving £1 million per year in dividends from a UK holding company and a retired American collecting $80,000 in U.S. investment income both pay the same flat amount — provided they qualify.

The regime lasts for a maximum of 15 years. During that period, participants are also exempt from IVIE (the Italian wealth tax on foreign real estate) and IVAFE (the Italian wealth tax on foreign financial assets), and they have no obligation to disclose foreign assets in the annual Italian tax return. Foreign assets transferred by gift or inheritance are not subject to Italian inheritance or gift tax — only Italian-situated assets remain within scope.

Italian-source income, however, is taxed under ordinary Italian rules and is not covered by the regime.

Three Tiers, Three Cohorts

The evolution of the regime has produced three distinct cohorts of taxpayers, each grandfathered at the rate applicable when they opted in:

Individuals who established Italian tax residence and opted into the regime before 10 August 2024 continue to pay €100,000 per year for the remainder of their 15-year term. Those who opted in between 10 August 2024 and 31 December 2025 pay €200,000 per year. Anyone who transfers Italian tax residence on or after 1 January 2026 is subject to the new €300,000 rate.

Italy has consistently respected the grandfathering principle across these changes: no existing participant has been required to pay more than the amount in force at the time they opted in. This is a meaningful commitment — and one potential entrants should factor into their timing decisions.

How to Qualify and Apply

Eligibility rests on one primary condition: the individual must not have been an Italian tax resident in at least nine of the ten tax years immediately preceding their transfer to Italy. Nationality is irrelevant — U.S. citizens, UK nationals, and third-country nationals all qualify on the same basis.

The option is exercised through the Italian income tax return for the first year of Italian tax residence (or, in some cases, through a prior ruling request to the Italian Revenue Agency). Timely payment of the substitute tax by 30 June each year is an essential condition: failure to pay terminates the regime. There is no possibility of partial payment or instalment.

Family members can be included under the regime, each subject to a separate €50,000 annual charge. “Family members” for this purpose generally means spouses and dependent children, though the perimeter should be confirmed on a case-by-case basis.

The U.S. Angle: A Crucial Caveat

For U.S. citizens, the regime works differently than for most other nationalities — and the difference matters. The United States taxes its citizens on worldwide income regardless of where they live. A U.S. citizen who pays €300,000 to Italy under the lump sum regime will still owe U.S. tax on all foreign-source income under IRS rules. The Italian substitute tax is not a foreign tax credit eligible for offset against U.S. income tax in the normal way, because it is a lump sum, not a tax computed on the income itself.

This does not make the regime useless for Americans, but it does mean the analysis requires careful modelling. In practice, the regime is most advantageous for U.S. citizens with very large amounts of foreign income — where the €300,000 flat charge is modest relative to what Italian progressive rates (up to 43%) would otherwise produce — and who can structure their U.S. position efficiently. Any U.S. citizen considering the regime should obtain specialist U.S. tax advice alongside Italian advice.

For UK nationals, the picture has also changed. The abolition of the UK non-domicile regime in April 2025 removed a longstanding alternative. Italy’s lump sum regime is now one of the few credible non-dom frameworks available to UK-resident HNWIs looking to relocate, alongside Malta and Portugal. The higher €300,000 cost reduces its attractiveness at the margin, but the combination of lifestyle, the 15-year horizon, and the inheritance tax shelter on foreign assets still makes Italy competitive for those with substantial non-Italian wealth.

Is the Higher Cost Still Worth It?

At €300,000 per year, the break-even point relative to ordinary Italian taxation has moved. Under standard Italian rates, €300,000 per year in tax corresponds roughly to a taxable income of approximately €800,000 to €900,000, depending on deductions. For individuals with foreign income well above that level, the regime continues to offer substantial savings. For those with foreign income in the €300,000–€600,000 range, the calculation is more delicate and depends on income type, applicable treaties, and individual circumstances.

What the regime continues to offer that no standard tax position can replicate is certainty and simplicity: one annual payment, no ordinary IRPEF computation on foreign income, no IVIE or IVAFE filings, and no foreign asset disclosure.

Final Considerations

The €300,000 lump sum regime remains one of the most attractive non-domicile frameworks available in Europe, despite its increased cost. For high-net-worth individuals with substantial foreign income — particularly investment portfolios, passive business income, or real estate returns outside Italy — the regime can deliver significant tax savings and meaningful administrative simplicity over a 15-year horizon.

The grandfathering principle also creates a window of opportunity for individuals who are already planning a move to Italy but have not yet formalised their tax residence: the €200,000 rate is definitively closed, but understanding the rules, timing the transfer correctly, and filing the option accurately in the first tax year are all critical steps that require professional guidance.

U.S. citizens face additional layers of complexity due to U.S. citizenship-based taxation, and should not assume that the Italian treatment resolves their U.S. obligations. UK nationals navigating post-non-dom planning may find Italy’s framework worth serious consideration, but the comparison with other jurisdictions should be made with up-to-date advice on each.

The Italian 7% Retiree Tax Regime: A Strategic Opportunity — Including for U.S. Citizens

The Italian 7% Retiree Tax Regime: A Strategic Opportunity — Including for U.S. Citizen

PDF memo here

Italy offers a highly attractive tax incentive for foreign retirees who choose to relocate to certain areas of Southern Italy. The regime, introduced by Article 24-ter of the Italian Income Tax Code, allows qualifying individuals to benefit from a 7% flat substitute tax on their foreign-source income for up to ten years.

The measure was designed to attract pensioners willing to establish their tax residence in smaller municipalities located in specific Southern regions. It combines a low and predictable tax burden with simplified compliance obligations, making it one of the most competitive retiree regimes currently available within the European Union.

Under this regime, individuals who receive a foreign pension and who have not been tax resident in Italy for at least five previous tax years may opt for a substitute tax equal to 7% on all foreign-source income. This includes not only pension income, but also foreign dividends, interest, capital gains and rental income. The substitute tax replaces ordinary progressive income taxation, which in Italy can exceed 40%, as well as regional and municipal surtaxes.

Italian-source income remains subject to ordinary taxation and is not covered by the 7% regime.

A decisive element of the regime is geographic location. The taxpayer must transfer tax residence to a municipality with fewer than 30,000 inhabitants located in one of the eligible Southern regions, such as Sicily, Calabria, Sardinia, Campania, Basilicata, Abruzzo, Molise or Puglia. If this territorial requirement is not met, the regime cannot be applied. The policy objective is clearly linked to encouraging demographic and economic revitalization in smaller Southern communities.Under Law No. 34 of March 11, 2026 (Article 26), the population threshold for eligible municipalities has been increased:

  • From 20,000 inhabitants ( previous ) → to 30,000 inhabitants (now)

This seemingly technical adjustment has a substantial practical impact:

  • 74 additional municipalities are now eligible
  • Broader geographic coverage across Southern Italy
  • Access to more developed towns with better infrastructure

Regions benefiting from the expansion include Campania, Sicily, Puglia, Sardinia, Abruzzo, Calabria and Molise.

Notably, newly eligible municipalities include internationally recognised locations such as:

  • Pompei
  • Noto
  • Ostuni
  • Milazzo

This marks a clear shift: the regime is no longer limited to small, often remote towns, but now includes fully functional urban centres.

An additional advantage of the regime concerns compliance obligations. During the period of application, foreign assets are exempt from Italian wealth taxes (IVIE on foreign real estate and IVAFE on foreign financial assets), and the taxpayer is exempt from the foreign asset reporting obligation normally required under Italian monitoring rules. This considerably simplifies annual tax compliance for retirees with diversified international holdings.

The regime can apply for up to ten consecutive years. It may be revoked by the taxpayer and automatically ceases if the eligibility conditions are no longer satisfied. Once terminated, it cannot be reactivated.

From a planning perspective, the regime can produce substantial tax savings. A retiree receiving significant foreign pension and investment income may reduce the effective Italian tax burden to a small fraction of what would otherwise apply under the ordinary progressive system. However, careful analysis remains essential. Double tax treaty interaction, foreign withholding taxes, and the timing of relocation during the tax year should all be evaluated before moving.

Special Considerations for U.S. Citizens

For U.S. citizens, the analysis becomes more complex because the United States taxes its citizens on worldwide income regardless of residence. A U.S. retiree relocating to Southern Italy under the 7% regime will still be required to file annual U.S. federal tax returns and report worldwide income.

The 7% Italian substitute tax does not eliminate U.S. taxation. Instead, coordination depends on the foreign tax credit (FTC) mechanism and the Italy–U.S. tax treaty.

In principle, the Italian 7% substitute tax qualifies as an income tax and may be creditable for U.S. purposes. However, the credit is subject to U.S. limitation rules. The foreign tax credit cannot exceed the portion of U.S. tax attributable to the same category of income. If the U.S. effective rate on that pension income exceeds 7%, a residual U.S. tax liability may remain.

In addition, differences in taxable base calculations between the two systems can affect the amount of usable credit. Each case requires modeling based on the nature of the pension (private pension versus U.S. Social Security), overall income levels, and treaty allocation rules.

Under the Italy–U.S. tax treaty, U.S. Social Security is generally taxable only in the United States. In such cases, the 7% regime would not override treaty allocation. Private pensions, however, may be taxed in Italy, triggering foreign tax credit considerations in the United States.

For U.S. retirees, therefore, the real question is not whether Italy taxes at 7%, but what the combined Italy–U.S. effective burden will be after applying treaty provisions and foreign tax credit limitations.

Final Considerations

The 7% Retiree Regime represents a powerful and predictable tax incentive for foreign pensioners willing to relocate to eligible Southern municipalities. For many non-U.S. retirees, it can significantly reduce overall taxation while simplifying compliance.

For U.S. citizens, the regime can still be attractive, but it requires coordinated cross-border planning. The headline 7% rate is only one part of the analysis. A proper evaluation must consider treaty interaction, U.S. foreign tax credit mechanics, and the overall combined tax position.

As with any international relocation, detailed planning is essential before making the move.

New Italian Inbound Workers Regime: Employer of Record Continuity and Extended Foreign Residence Requirement

New Italian Inbound Workers Regime: Employer of Record Continuity and Extended Foreign Residence Requirement

Italian Revenue Agency – Ruling No. 54/2026

The Italian Revenue Agency examined the application of the new inbound workers tax regime (Article 5, Legislative Decree No. 209/2023) in a case involving:

An Italian citizen resident in Switzerland for three tax years;

Employment abroad through a Swiss Employer of Record (EoR);

Relocation to Italy in 2025;

New employment in Italy for a different foreign operating company;

Formal employment contract signed with an Italian Employer of Record belonging to the same corporate group as the Swiss EoR.

The operating companies benefiting from the employee’s services were not related to each other.

The taxpayer argued that the ordinary three-year foreign residence requirement should apply, since the EoR performed only administrative/payroll functions and had no managerial authority.

Legal Framework

Under Article 5 of Legislative Decree No. 209/2023, the new inbound workers regime provides:

A 50% exemption on Italian-source employment income (up to EUR 600,000 annually);

A minimum foreign residence requirement of three tax years;

An extended requirement of six or seven tax years if, upon return, the employee works:

for the same employer, or

for a company belonging to the same corporate group (as defined under Article 2359 of the Italian Civil Code).

Position of the Revenue Agency

The Revenue Agency clarified that:

Continuity is assessed based on whether the employer (or group) before and after the relocation is the same;

This principle also applies when the formal employer is an Employer of Record;

It is irrelevant that the EoR performs only administrative functions;

It is irrelevant that the operating companies benefiting from the services are different and unrelated.

Since the Swiss and Italian Employers of Record belonged to the same corporate group, the Agency considered that continuity existed.

Conclusion

The ordinary three-year foreign residence requirement does not apply.

The taxpayer must satisfy the extended six-year foreign residence requirement to qualify for the new inbound workers regime.

Practical Implications

The ruling confirms a formal and structural interpretation of “group continuity,” focusing on corporate control relationships rather than on the substantive nature of the employment relationship.

This interpretation is particularly relevant for:

International mobility structures involving Employers of Record;

Multinational groups using payroll intermediaries;

Cross-border employment planning under the new Italian inbound workers regime.

Forfettario vs. Impatriati for U.S. Citizens in Italy: How Dual Taxation Shapes Expat Choices

Forfettario vs. Impatriati for U.S. Citizens in Italy: How Dual Taxation Shapes Expat Choices

For professionals and employees relocating to Italy, the regime forfettario and the regime degli impatriati are often seen as the two most attractive tax incentives.
From a purely Italian perspective, both regimes offer significant advantages.
However, for U.S. citizens, the decisive factor is not domestic taxation alone, but the interaction between Italian incentives and U.S. worldwide taxation.
This interaction profoundly affects the real economic outcome and, therefore, the strategic choices of expatriates.

The Dual Tax Framework
A U.S. citizen resident in Italy is subject to two tax authorities:
• The Italian system, administered by Agenzia delle Entrate, based on residence
• The U.S. system, administered by the Internal Revenue Service, based on citizenship
Both systems require the declaration of worldwide income.
As a result, any Italian tax benefit must be evaluated in light of its impact on U.S. taxation.

The Forfettario Regime in an International Context
Domestic Logic
The forfettario regime is designed as a simplified system for small professionals.
It applies a substitute tax and removes the need for detailed accounting.
Its structure is built around income containment and administrative ease.
Interaction with U.S. Rules
From the U.S. perspective:
• Income remains fully visible
• The substitute tax is largely ignored
• Taxation follows ordinary federal rules
However, the forfettario regime operates within an income ceiling that is structurally compatible with U.S. foreign income exclusions (FIE).
When residency requirements are met and currency conversion remains favorable, the entire Italian professional income may fall within U.S. exclusion mechanisms.
In these cases, the Italian benefit can be preserved at a global level.


The Impatriati Regime in an International Context
Domestic Logic
The impatriati regime reduces the taxable base of employment or professional income.
Only part of the income is subject to ordinary Italian taxation.
It is intended to attract skilled workers and managers.
Interaction with U.S. Rules
From the U.S. perspective:
• The full gross income is taxable
• The Italian reduction is ignored
• No structural coordination exists
The IRS does not recognize partial exemptions granted by foreign law.
It taxes economic income, not domestically reduced bases.
As a consequence, the portion exempted in Italy often becomes fully taxable in the United States, if above the FIE threshold.
Practical Implication
Under the impatriati regime:
• Italian taxes decrease
• U.S. taxes tend to increase proportionally
• Foreign tax credits weaken
In many cases, the Italian benefit is largely transferred to the U.S. tax base.
This makes the regime internationally inefficient for most U.S. citizens.

The Role of Exchange Rates
For both regimes, income must be converted into U.S. dollars for tax purposes.
Fluctuations in the EUR/USD rate may:
• Reduce the effectiveness of U.S. exclusions
• Increase residual U.S. taxation
• Destabilize long-term planning
This risk is more relevant for forfettario cases, where alignment with U.S. exclusions is essential.

Compliance and Risk Exposure
Both regimes require full U.S. reporting.
Relying solely on Italian compliance exposes expatriates to:
• Underreporting risks
• Accumulated liabilities
• Penalties and interest
• Difficult regularization procedures
The risk is structurally higher under the impatriati regime, where income levels are typically higher and credits weaker.

Conclusion
For U.S. citizens in Italy, the choice between forfettario and impatriati cannot be made on domestic grounds alone.
The forfettario regime may preserve its advantage when carefully integrated with U.S. exclusions and currency management.
The impatriati regime, while powerful domestically, is often neutralized internationally.
As a result:
• Forfettario supports globally efficient self-employment models
• Impatriati supports career-driven relocation with limited tax efficiency
For expatriates, the optimal decision depends less on Italian tax rates and more on long-term international coordination.
Without such coordination, both regimes risk becoming attractive on paper but ineffective in practice.

Please contact us for any further info !

Italy’s 2026 New-Resident Tax Regime: Key Changes for International Taxpayers

Italy’s 2026 New-Resident Tax Regime: Key Changes for International Taxpayers

Italy continues to offer a special tax regime for individuals transferring their tax residence to the country after a prolonged period abroad. Commonly referred to as the new-resident flat tax regime, this incentive is designed to attract high-net-worth individuals and internationally mobile taxpayers by providing certainty and simplification in the taxation of foreign income.

With the 2026 Budget Law, the regime has been confirmed but significantly recalibrated.

Eligibility

The regime is available to individuals who:

  • become tax resident in Italy; and
  • have not been Italian tax residents for at least 9 of the previous 10 years.

Once elected, the regime may apply for a maximum period of 15 years.

How the regime operates

Taxpayers opting for the regime are subject to:

  • a fixed annual substitute tax on foreign-source income;
  • ordinary taxation on Italian-source income.

Foreign assets and income covered by the regime are excluded from Italian wealth taxes and related reporting obligations, offering a high degree of administrative simplicity.

What changes from 2026

For individuals transferring tax residence from 1 January 2026, the annual flat tax amounts are increased as follows:

  • €300,000 per year for the main taxpayer;
  • €50,000 per year for each qualifying family member included in the election.

The increase represents a substantial adjustment compared to prior years and directly affects the overall cost of accessing the regime.

What remains unchanged

The reform does not alter:

  • the eligibility criteria;
  • the duration of the regime;
  • the scope of income covered, which remains limited to foreign-source income.

Strategic considerations

The 2026 changes confirm Italy’s intention to maintain the new-resident regime while narrowing its focus. The regime remains attractive for individuals with significant foreign income or complex international structures, but the higher fixed tax requires a careful evaluation of expected benefits versus cost.

For prospective new residents, advance tax planning is essential to assess:

  • effective tax savings compared to ordinary Italian taxation;
  • interaction with double tax treaties;
  • timing of the transfer of residence.

Conclusion

Italy’s new-resident tax regime remains a key instrument in international tax planning, but from 2026 it is clearly positioned as a selective regime for high-income taxpayers. Proper structuring and professional advice are crucial to ensure that the regime is both accessible and advantageous under the updated framework.

Italian “First Home” Tax Relief for Italian Nationals Abroad: Clarification by the Revenue Agency

With Ruling No. 312/2025, the Italian Revenue Agency clarified the scope of the “first home” tax relief for individuals who have transferred their residence abroad for work purposes and are registered with AIRE.

Following the amendments introduced by Decree-Law No. 69/2023, the tax benefit is no longer linked to citizenship but to objective criteria, focusing on the individual’s personal and professional connection with Italy.

The ruling confirms that a person who:

  • moved abroad for work reasons,
  • previously lived or carried out any form of activity in Italy for at least five years (not necessarily continuously),
  • does not own other residential properties purchased with first-home benefits,

may apply the “first home” tax relief even if the property is not located in the municipality of birth or last Italian residence.

In particular, the Revenue Agency recognizes that the concept of “activity” includes education and university studies, even if unpaid. Therefore, purchasing a residential property in the municipality where the taxpayer completed their entire educational and university path qualifies for the tax relief, provided all other legal requirements are met.

Importantly, in these cases:

  • there is no obligation to transfer residence to the municipality where the property is located,
  • the property does not need to be used as a primary residence.

This interpretation significantly broadens access to the “first home” tax relief for Italians working abroad, strengthening the relevance of substantial personal and formative ties with a specific Italian municipality

Italy Confirms: Early Redemption of Pension Funds Is Taxable in Italy, Even for Expats

Italy Confirms: Early Redemption of Pension Funds Is Taxable in Italy, Even for Expats

In November 2025, the Italian Revenue Agency published Ruling No. 296/2025, which clarifies a crucial point for anyone living abroad with an Italian complementary pension fund. According to the Agency, when a taxpayer requests a full early redemption of the fund — before reaching the pension age required to access the actual pension benefit — this payment cannot be treated as a “pension” under international tax treaties.

The ruling explains that, in such cases, the payout is considered income similar to employment income, because the individual has not yet matured a true pension right. As a consequence, the payment falls under the treaty article governing employment income, not the article governing pensions. This means that even if the person now lives abroad and is registered with AIRE, the amount remains taxable in Italy, since the underlying work that generated the fund contributions was carried out in Italy.

For expatriates, the practical implication is very clear: an early redemption of an Italian complementary pension fund is not taxed exclusively in the foreign country of residence. Unless you have already reached pension age and matured the right to an actual pension benefit, Italy keeps its taxing rights. In short, an “early cash-out” does not transfer taxation abroad.

You can read the full official text of Ruling No. 296/2025 here:
https://www.agenziaentrate.gov.it/portale/documents/20143/9425539/Risposta+n.+296_2025.pdf/a2df818f-0e04-cc48-3757-7820dcf30b3c

Thinking of Moving to Italy? New Rules Favor Applicants from the U.S. with Italian Heritage

Thinking of Moving to Italy? New Rules Favor Applicants from the U.S. with Italian Heritage

Italy has updated the Decreto Flussi to create an easier pathway for descendants of Italian citizens to enter Italy for work outside the annual immigration quotas. The reform targets people of Italian origin who live in countries with a significant Italian diaspora, including the United States, and makes it simpler for them to relocate to Italy for employment.

The key change is that these individuals are no longer subject to the tight quota system that traditionally limits non-EU entries for work. For those in the USA with Italian ancestry, this means the process becomes more accessible, faster, and less uncertain, because the quota cap no longer applies to them.

The exemption, however, does not eliminate the standard employment requirements. To benefit from this channel, the person must still have a valid job offer from an employer in Italy. The employer must request the nulla osta (work authorization) through the official immigration portal. Once approved, the worker must enter Italy and sign the employment contract within the legally required timeframe.

In practice, the reform removes the hardest bureaucratic barrier—the quota limitation—while keeping intact the need for a genuine employment relationship. It is designed to encourage the return or relocation of people with Italian roots, especially from countries like the United States, by streamlining entry procedures and reducing administrative bottlenecks.

Cross-Border Pensions and Inheritance: Insights from Italy’s Ruling 290/2025

Cross-Border Pensions and Inheritance: Insights from Italy’s Ruling 290/2025

The Italian Revenue Agency, through Ruling No. 290/2025, has clarified the tax treatment of a lump-sum payout received in 2024 by an Italian tax resident as the heir of a U.S. voluntary pension account.
The full ruling is available here:

In the ruling, the Agency explains that the liquidation of the U.S. pension account—despite being funded entirely through voluntary contributions and unrelated to the Italian pension system—must be treated in Italy as pension income. Consequently, the amount received by the heir is subject to separate taxation, following the same rules that would have applied had the payment been made to the deceased person.

A central aspect of the ruling concerns the Italy–U.S. tax treaty. The Agency concludes that this type of lump-sum payout does not fall under the treaty article on employment-related pensions but under the article on “Other Income.” This provision assigns exclusive taxing rights to the country of residence of the beneficiary, meaning that Italy alone has the right to tax the payment.

For this reason, the U.S. withholding tax applied to the distribution should not have been charged. The Agency instructs the beneficiary to request a refund from the U.S. tax authorities and, if the refund is denied, to consider starting the treaty’s Mutual Agreement Procedure.

In essence, the ruling confirms that the entire gross amount of the distribution is taxable only in Italy under separate taxation, and any U.S. withholding must be reclaimed.

Psychologist Bonus 2025: How It Works, Who Can Apply, and What’s New

Psychologist Bonus 2025: How It Works, Who Can Apply, and What’s New

Applications for the so-called “psychologist bonus” can be submitted until November 14, 2025. This incentive, managed by INPS (the Italian National Social Security Institute), aims to support individuals who wish to begin psychotherapy but face financial difficulties.

Applications must be submitted exclusively online, either through the INPS portal (“Contribution for Psychotherapy Sessions – 2025 Applications”) or via the Multichannel Contact Center.

The measure was introduced in response to the growing psychological distress that emerged after the COVID-19 pandemic and the ongoing social and economic challenges. Established in 2022 under Decree-Law No. 228/2021 (Article 1-quater, paragraph 3), the bonus became a permanent measure in 2023 through Law 197/2022.

Eligible applicants are Italian residents with a valid ISEE (Equivalent Economic Situation Indicator) not exceeding €50,000. The benefit can be requested only once per year.

The amount granted varies according to income level:

ISEE up to €15,000 → maximum contribution of €1,500;

ISEE between €15,000 and €30,000 → maximum contribution of €1,000;

ISEE between €30,000 and €50,000 → maximum contribution of €500.

Once the application period closes, INPS will draw up regional and provincial rankings, ordered by ISEE value (from lowest to highest). In the event of a tie, priority is given to the earliest application submitted.

Beneficiaries will receive an INPS notification specifying the amount granted and a unique personal code. The accredited psychotherapist will use this code when issuing the invoice, and INPS will pay the professional directly — not the applicant.

The bonus must be used within 270 days from the publication of the ranking; after that period, the assigned code and related amount will be automatically cancelled.

Understanding the Italian ISEE – Equivalent Economic Situation Indicator

Understanding the Italian ISEE – Equivalent Economic Situation Indicator

What is the ISEE?

The ISEE (Indicatore della Situazione Economica Equivalente) is the Equivalent Economic Situation Indicator, a tool used in Italy to assess a household’s overall financial condition.
It combines information about income, assets, family composition, and property ownership to produce a standardized index.

The ISEE does not represent an amount of money, but a score that reflects a family’s economic capability.
It is widely used by public authorities to determine eligibility for social benefits, tax reductions, and subsidized services.


What is it used for?

The ISEE is required in many situations, including:

  • Access to public childcare, schools, and universities (e.g., reduced tuition fees).
  • Applications for healthcare benefits and social assistance programs.
  • Discounts on utility bills (electricity, gas, water).
  • Applications for housing benefits or rent contributions.
  • Access to bonuses or economic aid (such as the Assegno Unico per i figli, “Universal Child Allowance,” or the Bonus Psicologo).

In short, the ISEE allows the government to ensure that financial aid and benefits are granted fairly — based on real economic need.


How the ISEE is calculated

The ISEE is based on two key components:

  1. Family income, including salaries, pensions, business income, unemployment benefits, etc.
  2. Family assets, including bank accounts, real estate, vehicles, and investments.

Both are adjusted according to the number and composition of family members (the so-called scala di equivalenza), which gives greater weight to families with more dependents or special conditions (such as disabilities).


How to obtain the ISEE

To get an ISEE certificate, you must complete a DSU (Dichiarazione Sostitutiva Unica) — a self-declaration that collects all relevant data.

You can obtain your ISEE in three main ways:

  1. Through a CAF (Tax Assistance Center):
    Bring your identification documents, fiscal code, latest tax return, and bank/property details.
    The CAF will prepare and submit the DSU on your behalf.
  2. Online through INPS (Italian Social Security Institute):
    • Access the INPS portal with your SPID, CIE, or CNS credentials.
    • Select “ISEE precompilato” (pre-filled ISEE).
    • Review or confirm pre-loaded data and submit.
    • The ISEE certificate is usually available within a few days.
  3. Through your accountant or authorized professional, who can file the DSU digitally and retrieve the ISEE for you.

Validity and updates

  • The ISEE certificate is valid until December 31 of the year in which it is issued.
  • It must be renewed every year, especially when applying for benefits or scholarships.
  • You can request an updated version (ISEE corrente) if your income changes significantly (e.g., job loss).

Final remarks

The ISEE is a cornerstone of Italy’s social and welfare system.
It ensures that public support is targeted and equitable, reflecting the real financial status of families.

For expats, students, and residents planning to apply for any kind of public benefit in Italy, obtaining the ISEE is a fundamental step — and often the first document required by public institutions.

Deferred bonuses and the end of the impatriate regime: the Italian Revenue Agency clarifies timing and taxation

Deferred bonuses and the end of the impatriate regime: the Italian Revenue Agency clarifies timing and taxation

The Italian Revenue Agency, through Ruling No. 274/2025, examined whether the impatriate regime can apply to deferred compensation — such as long-term incentive plans, stock options, or deferred cash bonuses — that are paid after the end of the preferential period and after the worker has moved abroad.
The question concerns employees who benefited from the impatriate regime while working in Italy but later left the country, receiving at a later stage certain deferred payments linked to their previous Italian employment. The key issue is whether such income, although economically connected to work performed in Italy during the eligible period, can still enjoy the tax relief once the regime has expired and the worker is no longer an Italian tax resident.

Agency’s reasoning and position
The Revenue Agency reaffirmed two guiding principles:

Cash principle: employment income is taxed when it is actually paid, not when it is earned. Therefore, if a deferred bonus or incentive is paid after the end of the five-year (or extended) impatriate period, or after the individual becomes non-resident, the preferential regime can no longer apply.

Source principle: even though the worker is no longer resident in Italy, the portion of income linked to work performed on Italian territory remains taxable in Italy as Italian-source income. In such cases, the Italian employer must operate the ordinary withholding tax, while the foreign country of residence will grant relief for any double taxation under the relevant tax treaty.

In summary
The Agency concluded that the impatriate regime is strictly temporal: it applies only to income received while the worker is both tax resident in Italy and within the benefit period. Deferred bonuses or stock plans paid later are still taxable in Italy — if connected to Italian work activity — but under ordinary taxation, without the impatriate exemption.

Phantom Share Plans in Italy

Phantom Share Plans in Italy

Nature and Legal Framework

Phantom share plans, also called virtual or shadow share plans, are long-term incentive arrangements that replicate the economic advantages of share ownership without involving the transfer of real equity. Participants do not receive actual shares or voting rights but are promised a future cash payment whose value depends on the increase in the company’s share value over a certain period.

These plans are typically used to reward and retain key employees, directors, or consultants, aligning their interests with the company’s performance while avoiding dilution of ownership. From a legal standpoint, phantom shares are contractual rights, not financial instruments, and are governed by general civil and employment law principles rather than by corporate law.


Tax Treatment in Italy

The tax classification of phantom share income depends on the beneficiary’s relationship with the company. For employees, the payment is treated as employment income under Article 49 of the Italian Income Tax Code (TUIR). For directors, it qualifies as income assimilated to employment income under Article 50, while for self-employed professionals or consultants it constitutes professional income under Article 53.

Taxation arises at the time of payment, not upon grant or vesting. The amount received is subject to ordinary IRPEF and related regional and municipal surcharges. When the recipient is an employee or director, the company acts as withholding agent and applies the corresponding social security contributions to INPS.

For professionals operating under a partita IVA, the income forms part of their professional earnings and is subject to social contributions either to Gestione Separata INPS or, where applicable, to the relevant Cassa di Previdenza professionale (for example, CPAs, lawyers and other regulated professions). VAT applies if the incentive is paid in connection with an activity performed under a VAT-registered business.

For the company, the cost of the phantom share payout is deductible for corporate income tax (IRES) purposes in the fiscal year in which the payment is made, pursuant to Article 95 TUIR. Since no actual shares are issued and no capital movement occurs, the plan does not trigger registration or capital duties.

Although the value of the payment is linked to share performance, the gain is always treated as income from employment or self-employment, never as a capital gain. This distinction determines both the applicable tax and social-security framework.


Interaction with the “Impatriate Regime”

Phantom share payments may, in some circumstances, benefit from Italy’s “regime degli impatriati” (the special tax regime for individuals transferring their tax residence to Italy). This regime provides for a partial exemption from IRPEF on income derived from employment or self-employment performed in Italy, at the percentage applicable under current law.

Because phantom share payments are considered remuneration directly connected with work activity, they may qualify for this favorable treatment if they relate to services performed in Italy after the individual has become an Italian tax resident and if payment occurs during the valid period of the regime.

If the phantom share plan instead relates to work carried out abroad before the transfer of residence, or if payment is made after the regime’s expiration, the incentive would fall outside the scope of the benefit and be fully subject to ordinary taxation. For this reason, it is crucial to document the link between the incentive and the Italian employment or professional activity, as well as to plan the timing of payment carefully.

Use of Cash for Travel Expense Reimbursements Incurred by Professionals and Billed to Clients ?

Use of cash for Travel Expense Reimbursements Incurred by Professionals and Billed to Clients?

1. Regulatory Premise

Starting from the 2025 tax period, the legislator introduced significant changes to the tax treatment of expense reimbursements billed by professionals to their clients. These updates affect two key areas:

  • the tax treatment for the professional;
  • the deductibility of the cost for the client (enterprise).

2. Tax Aspects for the Professional

2.1 Tax Relevance of the Reimbursement

Under Article 54, paragraph 2, letter b) of the Italian Income Tax Code (TUIR), reimbursements analytically billed by the client for expenses incurred by the professional do not contribute to taxable self-employment income. This means:

  • such reimbursements are not subject to income tax;
  • no withholding tax is due from the client.

2.2 Traceability Condition (new paragraph 2-bis)

The newly introduced paragraph 2-bis, added by Decree-Law 84/2025, states that the tax-exempt status of the reimbursement is conditional on the professional having paid the original expense using traceable payment methods. This condition is especially relevant when:

  • the reimbursement is not actually received (e.g. client insolvency);
  • the professional wishes to deduct the unreimbursed cost.

3. Tax Aspects for the Client

3.1 New Deductibility Rules (Article 108 TUIR)

Revised by the same Decree-Law 84/2025, Article 108 TUIR sets out in paragraphs 5-bis and 5-ter that:

  • Paragraph 5-bis: travel, lodging, and transportation expenses (including taxi services) incurred directly by the business are deductible only if paid using traceable means (e.g., bank transfers, credit cards, or systems listed in Article 23 of Legislative Decree 241/1997).
  • Paragraph 5-ter: this rule also applies to analytical reimbursements paid to professionals for expenses incurred during the execution of contracted services. Again, deductibility is conditional upon the client paying the professional via a traceable method.

3.2 Who Must Ensure Traceability?

The law refers generically to “payments”, but:

  • for expenses directly incurred by the enterprise (paragraph 5-bis), traceability concerns payments to the service provider;
  • for reimbursements to professionals (paragraph 5-ter), traceability applies to the payment made by the client to the professional, not to the original payment made by the professional.

4. Coordination with Article 54 TUIR

The rules align coherently:

  • Article 54 TUIR regulates the professional’s side, requiring them to use traceable methods only if they wish to avoid taxation or deduct unreimbursed expenses;
  • Article 108 TUIR applies exclusively to the client (enterprise) and requires traceability of the invoice payment.

There is no need for the professional to have used traceable methods for the client to claim the deduction.


5. Operational Considerations and Simplifications

5.1 No Verification Obligations for the Client

The client is not required to:

  • verify how the professional paid the expenses;
  • collect or store evidence related to the professional’s original payments.

It is sufficient that the invoice is paid using a traceable method, in order for the expense to be deductible.

5.2 Documentation Obligations for the Professional

Only the professional has an interest in ensuring payment traceability:

  • to exclude the reimbursement from their taxable income;
  • to deduct unreimbursed costs when applicable.

6. Final Remarks

  • The regulatory framework clearly distinguishes between the roles of the professional and the client.
  • Traceability is a condition for the client’s deduction, but it only applies to the invoice payment.
  • There is no obligation for the professional to use traceable payments to enable the client’s deduction.
  • The traceability obligation is relevant only for the professional’s own tax treatment.
  • The rules aim to simplify compliance for businesses, avoiding burdensome documentation of how the professional originally paid the expenses.

Extension of the “Impatriate Regime” for workers who moved to Italy in 2020: what happens after the first 5 years


🌍 Extension of the “Impatriate Regime” for workers who moved to Italy in 2020: what happens after the first 5 years

The so-called “impatriate regime” (Regime degli impatriati), ,aims to attract highly skilled workers to Italy by offering a significant tax incentive: partial tax exemption on employment, self-employment, and business income produced in Italy.


🔎 Standard duration: first 5 years

  • Workers who transferred their tax residence to Italy in 2020 benefited from the regime for five years, starting from the year they became tax residents in Italy.
  • For them, the last year of the initial benefit period was 2024.

📌 What happens after 2024?

As a rule, the regime expires after five years. However, Italian law allows an extension for an additional five years (up to a total of ten years), under specific conditions.


Conditions for the 5-year extension

To continue benefiting from a tax reduction from 2025 to 2029, the worker must meet at least one of the following conditions before the end of 2024:

1️⃣ Have at least one minor or dependent child, including those in pre-adoptive foster care.

2️⃣ Purchase a residential property in Italy after the move (or within the 12 months before the transfer).


💰 Tax benefit during the extension

  • During the first five years, eligible workers benefited from a 70% exemption on qualifying income (or even 90% for those working in southern Italy).
  • During the extension period, the tax exemption is reduced to 50%.
  • No lump-sum payment or additional contributions are required to access this extension (unlike the special rules for professional athletes).

📊 Summary table

PeriodExemptionConditionsPayment required?
First 5 years (2020–2024)70% (or 90% south)Residence abroad for ≥ 2 years + move to Italy + work mainly in ItalyNo
Additional 5 years (2025–2029)50%At least one minor child or residential property purchaseNo

💼 Procedural requirements

  • The worker must opt for the extension by indicating it in their 2025 Italian tax return (submitted in 2026).
  • It is advisable to inform the employer to ensure correct application of reduced tax withholdings.
  • Documentation proving the existence of the child or property ownership must be retained for potential tax audits.

📈 Example

Let’s assume:

  • A worker moved to Italy in 2020.
  • They have a minor child born in 2023.
  • Their last year of standard benefit is 2024.

In this case, they qualify to extend the regime from 2025 to 2029 with a 50% tax exemption, without paying any extra fee.


⚖️ Conclusion

✔️ Workers who moved to Italy in 2020 will see their initial 5-year benefit end in 2024.
✔️ If they have a minor child or bought a home in Italy, they can extend the benefit for another 5 years (2025–2029) at a 50% exemption rate.
✔️ No lump-sum contributions or additional costs are required.
✔️ Timely option and proper documentation are crucial to continue enjoying the benefit safely.


💬 Need support?

If you or your clients are eligible for the extension, it is highly recommended to plan in advance, check compliance, and prepare the necessary documentation.

Residence Registration: A Legal Obligation vs. a Voluntary Practice (like in the U.S)

Residence Registration: A Legal Obligation vs. a Voluntary Practice ( like in the U.S )

In many European countries (e.g., Germany, France, Italy), registering with the city or municipality is a legal obligation for all residents. This process, typically done shortly after moving into a new address, is essential because:

-It establishes your legal residence, which determines eligibility for public services (healthcare, education, local benefits).

-It allows local governments to maintain accurate population records.

-It connects you to local taxation systems and the correct voting district.

-It ensures you can receive official correspondence and perform key bureaucratic tasks (e.g., getting an ID, enrolling children in school).

Failure to register often results in administrative fines, difficulty accessing services, or even legal issues for residency-related processes (e.g., immigration compliance).

Contrast with the United States
In the U.S., there is no mandatory city registration system. The government does not maintain a centralized database of where every person lives. As a result:

-Proof of residency, as known in Europe, does not officially exist in a standardized way in the U.S.

-There’s no legal requirement to inform city or municipal authorities when you move.

-Instead, individuals must update their address with specific agencies when relevant (e.g., the DMV for driver’s licenses, local election boards for voting, IRS for taxes).

These updates are decentralized and rely on self-reporting, with little oversight unless fraud or benefits are involved.

This system is more flexible but creates gaps in population tracking and administrative coordination. It also means that residency is often “proven” by using ( usually more than one document is requested ) utility bills, lease agreements, or bank statements, since there’s no official certificate issued by a city.

When to Register
Within 20 days of moving to a new municipality (comune)

Where to Register
At the Ufficio Anagrafe (registry office) of the local municipality

Required Documents
-Valid ID or passport

-Tax code (Codice Fiscale)

-Proof of housing (rental contract, property deed, or hosting declaration)

-Proof of health insurance (for EU and non-EU citizens)

-Residence permit (for non-EU nationals)

Outcome
You are entered into the Anagrafe dei Residenti, Italy’s civil registry

-You receive a certificate of residence (certificato di residenza)

-Police verification may follow (they check if you actually live there)

NOTE : The above process does not automatically make you fiscally resident for the same year !

Fiscal Residency (Residenza Fiscale)
This refers to your tax residency status, governed by the Italian Revenue Agency (Agenzia delle Entrate). You are considered a fiscal resident if any one of the following is true for more than 183 days per solar year:

-Your registered legal residence is in Italy (from the Anagrafe – the process described above)

-Your habitual abode (physical presence) is in Italy

-Your center of economic or personal interests is in Italy

This determines:

-Where you pay income tax

-Whether you are taxed on worldwide income (if resident) or only Italian income (if non-resident)

4% social security surcharge on invoices : What is it ?

4% social security surcharge on invoices : What is it ?
If you’ve received an invoice from an Italian consultant or freelancer, and there’s a 4% charge added to the net amount, here’s what it means:

It is not a tax or a penalty
The 4% line item is not a fine or extra fee. It’s a social security-related charge, required or allowed by Italian law depending on the type of professional issuing the invoice.

Two possible cases – what it means for you

Case A – The professional is part of a regulated profession (e.g. architect, lawyer)
The 4% is a mandatory contribution to their professional pension fund.

It’s called the “contributo integrativo”.

Italian law requires the professional to charge it to the client, even if the client is not in Italy.

This 4% does not increase their taxable income. On this 4% there is no witholding tax but it has VAT

You simply pay it as part of the invoice — you don’t need to do anything else.

Case B – The professional is a freelancer without a professional order (e.g. designer, consultant)
The 4% is optional and is used to partially offset their INPS social security costs.

It’s allowed by INPS (the Italian social security institute).

In this case, it is included in their taxable income. So the 4% has witholding tax , and of course VAT

Again, as the client, you just pay it as shown — no further action required on your side.

Why is it on your invoice?
In both cases, the professional is simply complying with the rules of the Italian social security system. The 4% charge helps cover pension contributions and is a standard item in many invoices from Italian professionals.

It is not VAT, and it is not negotiable if it’s mandatory. If it’s optional (INPS case), it may have been previously agreed as part of the overall fee.

What do you need to do?
Nothing special. Just:

Pay the invoice including the 4% charge.

Make sure it’s listed clearly in the invoice breakdown.

No extra forms, declarations, or withholding obligations apply — especially if you are based outside of Italy.

Tax Return Document Checklist

Tax Return Document Checklist

As tax season approaches, it’s essential to prepare the required documentation in a timely and organized manner. Submitting all documents promptly and in full will significantly streamline the preparation and filing process, reduce back-and-forth communication, and help ensure you benefit from all available deductions.

We recommend printing this list ( click on the PDF logo above) and using it as a checklist while gathering your documents.

Please contact us if you have any doubts or if your personal or financial situation has changed during the year.

Personal Identification Documents
() Mod. 730 or Mod. Unico from the previous year (include F24 payment forms)
() Copy of your ID or passport
() Tax ID Number (Codice Fiscale)

Medical & Health-Related Expenses
() Pharmacy receipts (with Codice Fiscale and paid by card)
() Invoices for specialist visits and health tickets
() Invoices or receipts for veterinary expenses
() Funeral expenses

Financial and Employment Income
() Bank declaration for loan interest paid
() CUD (Certificazione Unica) for employment or pension income
() Foreign income tax returns and related tax payment documents

Property and Real Estate
() Cadastral report for properties purchased during the year
() Copies of any real estate sales or purchases made during the year

Deductions & Tax Credits
() ENEA Certifications (for energy savings 55% or 65%)
() Invoices and payments for renovation work (50%)
() Invoices for deductions related to furniture and appliances
() Payment confirmations for life insurance
() School tuition payment receipts
() Proof of payments for children’s sport activities (for those under 18)
() Receipts for donations to ONLUS (non-profit organizations)

Social Security & Contributions
() Payment proof for social security contributions
() Contributions for domestic service workers (INPS)

Foreign Assets
() Value and description of assets, equity, funds, and accounts held abroad
() Foreign financial availability required for IVAFE/IVIE declarations

How to Open a Partita IVA ( individuals )

How to Open a Partita IVA ( individuals )

What Is a Partita IVA ?
The Partita IVA (VAT number) is a unique 11-digit identification number used by the Italian tax authority (Agenzia delle Entrate) to track the financial activity of self-employed individuals, freelancers, and businesses.

If you’re planning to:

Work as a freelancer or consultant

Run a sole proprietorship (ditta individuale)

Launch a small business or e-commerce site

Provide professional services in Italy,

The process to open it

  1. Choose the Type of Activity and ATECO Code
    (Each activity is classified under an ATECO code, a standard Italian business classification.)
  1. Choose Your Tax Regime
    You must select the appropriate tax regime:

Regime Forfettario (Flat-tax): for revenues up to €85,000/year. Fewer obligations, simplified taxation.

Regime Ordinario Semplificato or Ordinario: for higher revenues or more complex businesses.

  1. Register with the Agenzia delle Entrate
    Fill out and submit form AA9/12.

You can do this:

Online, through our office

In person at your local Agenzia delle Entrate office

THIS is the form

4-Register with INPS
If you are self-employed, you must register with the appropriate INPS fund:

    Gestione Separata (for freelancers without a professional register)

    Artigiani e Commercianti (for traders and artisans)

    This is essential to pay your social security contributions.

      5-(Optional) Register with the Chamber of Commerce
      Required for some activities (e.g., artisans, retailers)

      Required Documents
      Valid ID (and permesso di soggiorno if non-EU)

      Italian tax code (codice fiscale)

      ATECO code and business details

      How Long Does It Take?
      VAT certificate : same day

      INPS and Chamber of Commerce: typically a few days to a week

      Please contact our Offices for any assistance.

      Regime Forfettario in Italy (2025): The Flat-Tax Option for Expats

      Regime Forfettario in Italy (2025): The Flat-Tax Option for Expats

      If you’re an expat living in Italy and planning to work as a freelancer, consultant, or solo entrepreneur, the Regime Forfettario (Flat-Rate Tax Regime) might be an appealing option. It offers simplified taxation, fewer bureaucratic obligations, and lower overall costs — but it’s not for everyone, and it’s mutually exclusive with the Regime degli Impatriati.

      Here’s everything you need to know about this regime in 2025, including how it interacts with social security (INPS) and why choosing between tax regimes requires a strategic decision.

      What Is the Regime Forfettario?
      The Regime Forfettario is a favorable tax scheme for individuals (sole traders and freelancers) with relatively modest revenues. It simplifies compliance, eliminates many traditional tax obligations, and applies a flat-rate taxation model.

      Who Qualifies in 2025
      To be eligible for the Regime Forfettario in 2025, you must meet all of the following conditions:

      -Revenues or professional fees must not exceed €85,000 in the previous tax year.

      -Personnel costs (e.g., employees or collaborators) must stay under €20,000.

      -Additional income from employment or pensions must not exceed €35,000.

      -You must not control or participate in a company that operates in the same business sector.

      -Your activity must not be predominantly for a current or former employer.

      Who Is Excluded?


      You cannot use this regime if:

      -You surpass the income or personnel cost thresholds.

      -You operate in specific excluded sectors (e.g., real estate or financial investment).

      -You are also eligible for and using the “Regime degli Impatriati” — these two tax regimes cannot be combined.

      How Taxation Works
      – A flat tax rate of 15% is applied to a percentage of your gross income, called the “coefficiente di redditività” (profitability coefficient). This varies by activity (usually 40%–78%).

      Startups that meet certain conditions (e.g., no professional activity in the last 3 years) may qualify for a reduced 5% rate for the first 5 years.

      • No VAT obligations, no withholding tax on invoices, no IRAP (regional tax).

      INPS (Social Security) Considerations
      All self-employed workers in Italy must contribute to INPS, the national social security system. The way this works depends on your profession:

      Freelancers (without professional association)


      -Enrolled in the Gestione Separata INPS.

      -Contribution rate in 2025: approximately 26.07% of taxable income.

      -Taxable income = Gross revenue × profitability coefficient.

      Artisans and Traders
      Enrolled in the Artigiani e Commercianti INPS fund.

      – Pay a fixed minimum contribution (~€4,500–€4,800 annually), plus a 24% rate on income above €17,500.

      -Contributions are tax-deductible under the flat-rate regime.

      Example: Freelance Consultant with regular 15% tax rate
      Gross revenue: €50,000

      Coefficient of profitability (consulting): 78%

      Taxable base: €50,000 × 78% = €39,000

      Income tax (15%): €5,850

      INPS (26.07% of €39,000): €10,170

      Net income: ~€33,980

      Regime Forfettario vs. Regime degli Impatriati
      If you’re an expat recently relocated to Italy, you may also be eligible for the Regime degli Impatriati, a tax incentive offering:

      -50% tax exemption on employment or self-employment income

      -Valid for 5 years, extendable in some cases

      However, you must choose between the two — they are mutually exclusive:

      The Regime Forfettario is better suited for low to mid-income freelancers or those seeking simplicity.

      The Regime degli Impatriati may be more beneficial for higher earners or structured professionals with larger income streams.

      Key Decision Factors
      Expected gross income

      -Type of work (employment vs freelance)

      -Professional and personal tax residency status

      -Long-term plans in Italy

      Be Careful: You Might Lose Personal Tax Deductions

      One lesser-known downside of the Regime Forfettario is that you may not benefit from common tax deductions (known in Italy as oneri detraibili) if you don’t have other income subject to ordinary progressive taxation (IRPEF).

      Why?
      The Regime Forfettario applies a substitute tax (flat rate of 15% or 5%) instead of IRPEF.

      This means you’re not part of the regular income tax system, so you don’t get to offset deductible expenses like:

      Medical expenses

      Rent or mortgage interest

      University fees

      Dependent family expenses

      Contributions to pension schemes beyond INPS

      When Does This Matter?
      If you:

      Only have income under the Regime Forfettario, and

      Don’t have other income taxed under the standard IRPEF system (like employment income, pension, or property rentals),

      …then your deductible expenses can’t be used, because there’s no IRPEF to offset them against.

      How to Retain Some Deductions
      If you have dual income (e.g., freelance income under Forfettario and salaried income taxed normally), you can still benefit from deductions, but only on the IRPEF-taxed portion.

      In some cases, it might be worth evaluating whether staying in the ordinary tax regime allows you to recover more through deductions, especially if your deductible expenses are high.

      Final Advice
      The Regime Forfettario is one of the most expat-friendly options for solo professionals starting a business in Italy. However, choosing between this and the Regime degli Impatriati can significantly impact your net earnings and tax liability.

      Please consult us for any further details !

      Understanding Italy’s E-Invoicing System: A Guide to Fattura Elettronica

      What is the Fattura Elettronica?
      The Fattura Elettronica is the mandatory electronic invoicing system in Italy for transactions between businesses (B2B), consumers (B2C), and public authorities (B2G). It replaces traditional paper and PDF invoices and is part of Italy’s strategy to fight tax evasion, automate VAT reporting, and streamline compliance.

      How Does It Work?
      Invoices are issued in a specific XML format, transmitted and validated via the Sistema di Interscambio (SdI), the central invoicing platform operated by the Italian Revenue Agency.

      The process includes:
      -Generating the invoice in XML format according to official specifications

      -Transmitting the invoice to SdI via PEC, web portal, or accredited software

      -Validation and delivery by SdI to the recipient

      -Receiving notification of acceptance or rejection

      -Archiving the invoice digitally for 10 years in compliance with Italian law

      Only invoices that go through SdI are considered valid for VAT and legal purposes.

      Obligations for Foreign Businesses
      -Foreign entities with a fiscal representative in Italy: must issue e-invoices via SdI

      -Foreign entities identified via “identificazione diretta” (direct VAT registration): currently not required to use SdI, but may still choose to do so

      Our Support
      To simplify the process, our firm provides a secure online platform that allows clients to:

      -Issue compliant electronic invoices in XML format

      -Send them directly to the SdI

      -Receive electronic invoices from Italian suppliers

      -Monitor delivery statuses and notifications

      -Digitally archive invoices in compliance with the legal requirements

      This service is especially helpful for foreign entities needing assistance navigating the Italian e-invoicing system with full compliance and minimal complexity.

      Necessary documents for your yearly Tax Return

      Tax season is fast approaching, please find a list of the Documents we need to receive to prepare your Tax Return:

      Mod. 730 or Mod. Unico of the previous year and payment forms F24.
      Copy of your ID/passport and Tax ID Number ( Codice Fiscale )

      Pharmacy receipts ( with your Codice Fiscale and paid by credit/debit card)
      Invoices for specialist visits, health tickets Invoices / receipts for medicines and veterinary expenses
      Funeral expenses

      Loan interest paid ( we need the bank declaration )
      CUD attesting your employment / retirement income
      Copies of ENEA Certifications, for energy savings of 55% and 65%
      Copy of renovation costs for recovery 50% plus deductions for Furniture and Appliances.
      Payment for life insurance costs
      Payment for school tuition costs

      Expenses for sport activities for children up to the age of 18
      Payments made to Onlus

      Payment of social security contributions

      Cadastral report for properties purchased during the year
      Copies of any real estate purchases / sales occurred during the year
      Contributions for domestic service workers
      Copy of any foreign income tax returns and related tax payments
      Value and description of assets / funds / equity investments / financial availability held abroad

      That’s the general list. Please contact us for any doubt !

      How to chose and setup a Corp.

      In Italy, setting up a company follows specific legal and bureaucratic procedures. Below is a breakdown of different types of companies in Italy and how to set them up, based on Italian corporate law.


      1. Sole Proprietorship (Ditta Individuale)

      A Ditta Individuale is a one-person business where the owner is personally responsible for all debts.

      Pros:

      • Simple and low-cost to set up
      • Minimal bureaucratic requirements
      • Profits taxed as personal income

      Cons:

      • Unlimited liability (owner’s personal assets are at risk)
      • Harder to access funding and investment
      • Less credibility compared to corporations

      How to Set Up a Ditta Individuale:

      1. Choose a Business Name (optional, default is the owner’s name).
      2. Register with the Chamber of Commerce (Camera di Commercio).
      3. Obtain a Partita IVA (VAT Number) from the Agenzia delle Entrate.
      4. Register with INPS (National Social Security Institute) for pension contributions.
      5. Register with INAIL (Insurance for workplace accidents) if applicable.
      6. Open a Business Bank Account.
      7. Issue Electronic Invoices (mandatory in Italy for B2B and B2G).

      2. General Partnership (Società in Nome Collettivo – SNC)

      A SNC is a partnership where all partners share equal liability for debts.

      Pros:

      • Simple and flexible management
      • No minimum capital required
      • Direct taxation (partners pay personal income tax)

      Cons:

      • Unlimited personal liability for all partners
      • Joint responsibility for debts

      How to Set Up an SNC:

      1. Draft a Partnership Agreement (Atto Costitutivo) with a notary.
      2. Register with the Chamber of Commerce.
      3. Obtain a Partita IVA from the tax office.
      4. Register with INPS and INAIL.
      5. Deposit the company documents at the Registro delle Imprese.
      6. Open a Business Bank Account.

      3. Limited Partnership (Società in Accomandita Semplice – SAS)

      A SAS has two types of partners:

      • General partners (Soci Accomandatari): Have full liability.
      • Limited partners (Soci Accomandanti): Only liable for the amount they invested.

      Pros:

      • Allows silent investors with limited risk
      • Less strict regulations than corporations

      Cons:

      • General partners bear full liability
      • More complex structure than SNC

      How to Set Up an SAS:

      1. Draft the company statutes and sign before a notary.
      2. Register with the Chamber of Commerce.
      3. Obtain a Partita IVA.
      4. Register with INPS and INAIL.
      5. Deposit company documents with the Registro delle Imprese.

      4. Limited Liability Company (Società a Responsabilità Limitata – SRL)

      An SRL is the most common corporate structure in Italy, offering limited liability to shareholders.

      Pros:

      • Shareholders’ liability is limited to their investment
      • Easier to attract investors
      • More professional credibility

      Cons:

      • Higher setup and maintenance costs
      • Stricter regulations than partnerships
      • Mandatory accounting and annual financial statements

      How to Set Up an SRL:

      1. Draft Articles of Association (Atto Costitutivo) with a notary.
      2. Deposit Minimum Share Capital (€10,000 for a standard SRL, €1 for an SRLS).
      3. Register with the Chamber of Commerce.
      4. Obtain a Partita IVA.
      5. Register with INPS and INAIL.
      6. Open a Business Bank Account.
      7. Appoint a Legal Representative.

      5. Simplified Limited Liability Company (Società a Responsabilità Limitata Semplificata – SRLS)

      A SRLS is a simplified version of an SRL, designed to be easier and cheaper to set up.

      Pros:

      • Lower setup costs (no notary needed)
      • Minimum capital of €1
      • Faster bureaucratic process

      Cons:

      • Less flexibility in structuring the company
      • More difficult to raise capital
      • Limited credibility for large contracts

      How to Set Up an SRLS:

      1. Use the standard government-approved statute (Atto Costitutivo).
      2. Register with the Chamber of Commerce.
      3. Deposit share capital (€1 to €9,999).
      4. Obtain a Partita IVA.
      5. Register with INPS and INAIL.
      6. Open a Business Bank Account.

      6. Joint-Stock Company (Società per Azioni – SPA)

      An SPA is a large-scale company where ownership is divided into shares.

      Pros:

      • Limited liability for shareholders
      • Can raise capital from investors and public markets
      • Best suited for large businesses

      Cons:

      • High setup costs (€50,000 minimum capital)
      • Strict regulations and reporting requirements

      How to Set Up an SPA:

      1. Draft the Articles of Association with a notary.
      2. Deposit the minimum capital (€50,000).
      3. Register with the Chamber of Commerce.
      4. Appoint a Board of Directors.
      5. Register with INPS and INAIL.
      6. Open a Business Bank Account.
      7. Submit annual financial reports.

      VAT Treatment of Expense Recharges Incurred by an Italian Company to Its European Parent Company

      VAT Treatment of Expense Recharges Incurred by an Italian Company to Its European Parent Company

      With Ruling No. 6/E of February 11, 1998, the Tax Administration reaffirmed that, from a civil law perspective, the relationship between the active party and the passive party in the recharging of costs should be classified as a mandate without representation. However, for VAT purposes, the operation falls within the scope of Article 3, third paragraph, of Presidential Decree No. 633/72, which states that the services rendered or received by agents without representation (SIT) are considered services even in the relationship between the principal and the agent

      What is the correct VAT treatment for this service (i.e., how should the invoice be issued)?

      In theory, the cost recharge could be treated in two different ways:

      1. As a general service, autonomously subject to VAT and unrelated to the nature of the individual services received.
      2. As a specific service, maintaining the same nature as the services originally received.

      If we adopt Option (1), the situation would be relatively simple:
      We would issue an invoice for “general cost recharge incurred in relation to the seconded employee” (or a similar description), out of scope for VAT under Article 7-ter of Presidential Decree 633/1972, with the statement “reverse charge” included on the invoice.

      However, the Tax Administration has a different view.

      According to the aforementioned Ruling No. 6/E of February 11, 1998:

      It is considered that this provision not only qualifies the transaction carried out by the agent without representation as a service but also achieves the broader purpose of establishing a VAT framework based on a “fictio iuris” (legal fiction). This legal fiction fully aligns the services rendered or received by the agent with those rendered by the agent to the principal. The alignment also extends to the nature of the services, meaning that the services rendered by the agent to the principal cannot be considered a simple intermediary role but must have the same nature as the original services received or provided by the agent on behalf of the principal.

      By reaffirming that the cost recharge constitutes a service, the ruling clarifies that the recharged cost retains the same intrinsic nature as the service originally received by the agent (SIT) and subsequently recharged to the principal (SEU).

      Implications

      This ruling has significant implications, as it requires us to analyze each individual service received, determine its correct VAT treatment, and then apply the corresponding VAT treatment to the recharge.

      • General Rule: Generic services follow the VAT territoriality rule, meaning they are subject to VAT in the country of the recipient (SEU).
        • In this case, the services should be re-invoiced as an out-of-scope VAT transaction under Article 7-ter of Presidential Decree 633/1972, with the mention “reverse charge” on the invoice.

      However, subsequent articles of Presidential Decree 633/72 introduce exceptions for specific types of transactions:


      VAT Treatment of Different Types of Costs in the Recharge

      Real Estate Rental

      • VAT territoriality rule: Rental of real estate follows the territoriality principle of the location of the property (Article 7-quater, paragraph 1, letter a, DPR 633/72).
      • Since the property is in Italy, the service is subject to Italian VAT (generally exempt under Article 10, DPR 633/72).
      • Recharge to the German parent company: It could be considered out of scope for VAT under Article 7-ter (if classified as a generic service provided to an EU taxpayer).

      Long-Term Car Rental (Article 7-sexies, DPR 633/72)

      • VAT territoriality: Determined by the location of the recipient.
      • In this case, the recharge is subject to the reverse charge mechanism.

      Travel Expenses (fuel, tolls, train, flight, taxi, etc.)

      • Same VAT treatment: Reverse charge applies.

      Restaurant Expenses

      • Meals are classified as services tied to the place of performance (Article 7-quater, letter c, DPR 633/72).
      • If the meal is consumed in Italy: The service is subject to Italian VAT.
      • Recharge to the parent company: The recharge does not change VAT territoriality, so it remains subject to Italian VAT (reverse charge does not apply).

      Hotel Expenses

      • Hotel services are subject to VAT where they are provided (Article 7-quater, letter a, DPR 633/72).
      • If the stay is in Italy: The service is subject to Italian VAT.
      • Recharge to the parent company: The cost remains subject to Italian VAT.


      Final Consideration: Salary/Wage Recharges

      With Tax Ruling No. 38 published on February 18, 2025, the Italian Tax Authority confirmed the new VAT framework for personnel secondment.

      • Article 16-ter of Decree Law 131/2024 establishes that secondment of personnel is considered a service subject to VAT when there is a direct link between the service provided and the consideration received.
      • This law abolishes Article 8, paragraph 35 of Law 67/88, which previously excluded personnel secondment from VAT when the reimbursement only covered actual costs without a “mark-up.”
      • The new rule applies only to secondment agreements signed or renewed from January 1, 2025.

      If further clarification is required, a detailed case-by-case assessment is recommended.

      How a Mortgage Works in Italy: Legal Aspects

      A mortgage in Italy (mutuo ipotecario) is a legal contract between a borrower and a lender, typically a bank, to finance the purchase of real estate. The process is regulated by Italian civil and banking laws, ensuring transparency and security for both parties. Below is a breakdown of how a mortgage legally works in Italy.


      1. Legal Framework & Regulations

      In Italy, mortgages are primarily governed by:

      • Italian Civil Code (Codice Civile) – Establishes the legal principles of contracts, property rights, and obligations.
      • Consolidated Banking Act (Testo Unico Bancario – TUB) – Regulates financial institutions and banking operations.
      • Consumer Credit and Mortgage Directives (EU Regulations) – Ensures fairness and transparency in lending practices.

      Banks must comply with these regulations when offering mortgages to individuals and businesses.


      2. Mortgage Structure & Key Elements

      A mortgage in Italy is legally composed of the following elements:

      A. Loan Agreement (Contratto di Mutuo)

      This is a legally binding contract between the borrower (mutuatario) and the lender (mutuante), specifying:
      ✔️ Loan amount (capitale)
      ✔️ Interest rate (fixed, variable, or mixed)
      ✔️ Repayment period (durata del mutuo)
      ✔️ Installments & payment schedule
      ✔️ Any penalties for late payment or early repayment

      B. Mortgage Registration (Ipoteca)

      A mortgage is secured by a lien on the property. This means:
      🏡 The bank registers a first-degree mortgage on the property at the Land Registry (Conservatoria dei Registri Immobiliari).
      ⚖️ If the borrower defaults, the bank has the right to foreclose and sell the property to recover the debt.
      📝 The mortgage remains registered until the loan is fully repaid.

      C. Notary Role (Notaio)

      A public notary plays a crucial legal role in the mortgage process:
      📜 Drafts and authenticates the mortgage deed (atto di mutuo ipotecario).
      🔎 Performs due diligence on the property, ensuring no legal disputes or outstanding debts.
      🏛 Registers the mortgage at the Land Registry.

      Without the intervention of a notary, the mortgage is not legally valid.


      3. Legal Steps to Obtain a Mortgage

      Step 1: Pre-Approval & Financial Evaluation

      • The borrower submits financial documents to the bank (income proof, credit history, tax returns).
      • The bank assesses the borrower’s financial stability and loan eligibility.

      Step 2: Property Due Diligence & Appraisal

      • A property valuation (perizia immobiliare) is conducted by a bank-appointed surveyor.
      • The notary checks the property’s legal status and ensures it has a clean title.

      Step 3: Signing the Mortgage Deed

      • The borrower and lender sign the mortgage contract (atto di mutuo) in front of a notary.
      • The contract is registered with the Land Registry, officially establishing the mortgage.

      Step 4: Funds Disbursement & Property Transfer

      • Once the mortgage is registered, the bank disburses the loan.
      • If the loan is for purchasing a home, the funds are typically transferred directly to the seller.

      4. Default & Legal Consequences

      If a borrower fails to meet repayment obligations:
      ⚠️ The bank can initiate judicial foreclosure (pignoramento immobiliare).
      ⚠️ The property may be auctioned through the court to recover the outstanding debt.
      ⚠️ In some cases, the borrower may negotiate debt restructuring (rinegoziazione del mutuo) with the bank.


      5. Early Repayment & Loan Portability

      • Early Repayment (Estinzione Anticipata) – Under Italian law, borrowers can repay their mortgage early, often without penalties (except for older contracts).
      • Mortgage Portability (Surroga del Mutuo) – Allows borrowers to transfer their mortgage to another bank for better terms, free of charge.

      Final Thoughts

      A mortgage in Italy is a well-regulated financial product that involves strict legal procedures to protect both the borrower and the lender. The presence of a notary, mortgage registration, and banking regulations ensures transparency and compliance. Anyone considering a mortgage in Italy should seek legal and financial advice to navigate the process effectively.

      Taxation of Income for Italian Residents Who Are U.S. Citizens

      Understanding Tax Obligations for Dual Tax Residents

      Italian residents who are also U.S. citizens face a unique and complex tax situation, as they are subject to taxation by both Italy and the United States. This article provides an overview of the key aspects of their tax obligations, double taxation treaties, and potential tax planning strategies.

      1. The U.S. Tax System and Its Implications

      The United States follows a citizenship-based taxation system, meaning that all U.S. citizens, regardless of where they reside, must file and potentially pay U.S. taxes. This includes Italian residents who hold U.S. citizenship.

      Key U.S. tax obligations include:

      • Filing an annual U.S. tax return (Form 1040), reporting worldwide income.
      • Declaring foreign bank accounts via FBAR (FinCEN Form 114) if the total value of all foreign accounts exceeds $10,000.
      • Filing Form 8938 (FATCA requirements) if foreign financial assets exceed certain thresholds.
      • Reporting foreign business interests through Form 5471 or Form 8865, if applicable.

      2. The Italian Tax System and Residency Rules

      Italy imposes taxes based on residency, meaning individuals who are considered Italian tax residents must pay taxes on their worldwide income. A person is considered a resident for tax purposes if they meet any of the following criteria:

      • They are registered in the Anagrafe (Resident Registry) for most of the tax year.
      • They spend more than 183 days in Italy within a calendar year.
      • Their principal place of business or economic interests is in Italy.

      As a result, U.S. citizens residing in Italy are subject to Italian income tax (IRPEF), which applies progressively, as follows:

      Income Bracket (€)Tax Rate (%)
      0 – 28,00023%
      28,001 – 50,00035%
      Over 50,00043%

      3. The U.S.-Italy Tax Treaty and Avoiding Double Taxation

      To prevent double taxation, the U.S.-Italy Tax Treaty offers mechanisms to mitigate tax burdens:

      • Foreign Tax Credit (FTC): The U.S. allows citizens to credit taxes paid to Italy against their U.S. tax liability, reducing the risk of double taxation.
      • Foreign Earned Income Exclusion (FEIE): U.S. citizens who meet the physical presence or bona fide residence test can exclude up to a specified amount ($120,000 in 2023) of foreign-earned income.
      • Totalization Agreement: This determines which country’s social security system applies to a taxpayer, depending on employment circumstances.

      4. Special Tax Regimes for Foreigners in Italy

      Certain foreign residents, including U.S. citizens moving to Italy, may benefit from preferential tax regimes, such as:

      • Regime Impatriati: Offers a tax reduction (70-90%) on employment income for highly skilled workers relocating to Italy.
      • Flat Tax Regime for New Residents: A fixed tax of €100,000 per year on foreign income, available for wealthy individuals.
      • Pensioner Tax Regime: Retired individuals moving to specific southern Italian regions may benefit from a 7% flat tax on their foreign income.

      5. Practical Tax Planning Considerations

      To navigate these complex obligations efficiently, U.S. citizens residing in Italy should consider the following:

      • Work with tax professionals who understand both U.S. and Italian tax laws.
      • Monitor foreign financial accounts to comply with FATCA and FBAR rules.
      • Optimize tax credits and exclusions to minimize overall tax liability.
      • Plan for social security contributions, as Italy and the U.S. have different systems.

      Conclusion

      Italian residents who are also U.S. citizens must carefully manage their tax responsibilities to avoid penalties and optimize their tax situation. By leveraging tax treaties, special regimes, and professional advice, they can ensure compliance while minimizing double taxation.

      How to Get a Mortgage in Italy: A Step-by-Step Guide

      Buying property in Italy is an exciting journey, whether you’re moving there, looking for a second home, or making an investment. If you need a mortgage (mutuo), the process can seem a bit daunting, especially if you’re not familiar with the Italian banking system. This guide will walk you through everything you need to know, in a clear and simple way.


      1. Understanding Mortgages in Italy

      Mortgages in Italy come in different types, so it’s important to choose the right one based on your financial situation and long-term plans.

      🏡 Fixed-rate mortgage – The interest rate stays the same for the entire loan term, making it a safer option if you prefer stability.
      📉 Variable-rate mortgage – The interest rate fluctuates based on market trends, which can mean lower payments at times but also potential increases.
      🔄 Mixed-rate mortgage – A combination of fixed and variable rates, usually starting as fixed and switching to variable after a few years.
      💰 Interest-only mortgage – This is less common, but some banks allow you to pay only the interest initially, with the full amount due later.


      2. Who Can Apply for a Mortgage in Italy?

      Both residents and non-residents can apply for a mortgage, but the conditions vary:

      Italian residents – Usually get the best terms, with loans covering up to 80% of the property’s value.
      EU citizens & foreigners with Italian residency – Similar advantages to residents, as long as they have stable income in Italy.
      Non-residents – Can still get a mortgage, but banks are more cautious. Typically, they finance only 50%-60% of the property value, and interest rates may be slightly higher.

      💡 Tip: Some Italian banks specialize in mortgages for foreigners, so it’s worth shopping around!


      3. What You Need to Apply for a Mortgage

      Italian banks require a set of documents to evaluate your mortgage application. Here’s what you’ll typically need:

      📌 Valid ID – A passport or Italian ID card.
      📌 Codice Fiscale (Italian Tax Code) – Essential for any financial transactions in Italy. You can get it from the Agenzia delle Entrate or your consulate.
      📌 Proof of Income – Recent salary slips, an employment contract, or tax returns if you’re self-employed.
      📌 Bank Statements – Usually from the last 3-6 months, to prove financial stability.
      📌 Credit History – Some banks check your credit score, especially if you’re applying from abroad.
      📌 Deposit – You’ll typically need at least 20%-50% of the property’s value, depending on your residency status.
      📌 Property Documents – The seller must provide official paperwork confirming the property’s legal standing.

      💡 Tip: Some banks might require life insurance as part of the mortgage agreement, so be prepared for that possibility.


      4. How to Apply for a Mortgage

      Once you’ve found the perfect home, here’s how the mortgage process works:

      Step 1: Choose the Right Lender & Get Pre-Approval

      🏦 Compare different banks or work with a mortgage broker who can help you find the best deal.
      📋 Getting pre-approval (approvazione preventiva) gives you an idea of how much you can borrow before committing to a property.

      Step 2: Submit Your Application

      📑 Provide all the required documents, including proof of income, tax records, and details about the property.
      🔎 The bank will analyze your financial situation to determine if you qualify.

      Step 3: Property Valuation & Legal Checks

      🏡 A surveyor (appointed by the bank) will inspect the property to confirm its value.
      📝 The bank will check for any legal issues, such as outstanding debts or disputes on the property.

      Step 4: Approval & Signing the Mortgage Contract

      ✅ Once approved, the bank will issue a binding offer, detailing the loan amount, interest rate, and repayment terms.
      ✍️ You will sign the final mortgage agreement in front of a notary (notaio), along with the property purchase deed.

      Step 5: Funds Transfer & Final Steps

      💰 The bank releases the loan amount—either directly to the seller or through an escrow process with the notary.
      🏡 Congratulations! The property is officially yours, and the mortgage is now active.


      5. Costs & Fees to Consider

      In addition to your deposit and monthly payments, here are some extra costs to keep in mind:

      💶 Bank fees – Usually 1%-2% of the loan amount.
      📜 Notary fees – Typically 1%-2% of the property price.
      🏛 Registration taxes & stamp duty – Costs vary based on the property type and whether you’re a resident.
      🏡 Surveyor fees – Around €300-€500 for the property valuation.
      💼 Mortgage broker fees – If you use a broker, they may charge a commission.

      💡 Tip: Some banks offer special deals for first-time buyers, so ask about any promotions or fee reductions!


      6. Tips for a Successful Mortgage Application

      ✔️ Show stable income – Banks prefer applicants with a steady job or a well-established business.
      ✔️ Improve your credit history – If possible, pay off any debts before applying.
      ✔️ Work with a local expert – A mortgage broker or real estate agent can help navigate the process, especially if you’re a foreign buyer.
      ✔️ Consider a higher deposit – Offering more upfront can improve your chances of approval and may secure better interest rates.

      USA – Beneficial Ownership Information (BOI) Report

      Beneficial Ownership Information (BOI) Report: Overview & Due Date

      The Beneficial Ownership Information (BOI) Report is a filing requirement introduced under anti-money laundering (AML) laws to increase transparency in corporate structures. It mandates companies to disclose details about individuals who ultimately own or control them.

      Who Needs to File the BOI Report?

      Entities subject to the BOI reporting requirement typically include:

      • Corporations
      • Limited liability companies (LLCs)
      • Other entities registered with government authorities
      • Some trusts and partnerships (depending on jurisdictional rules)

      What is Beneficial Ownership?

      A beneficial owner is an individual who:

      1. Directly or indirectly owns 25% or more of the entity’s shares, voting rights, or capital; OR
      2. Exercises significant control over the entity, even without direct ownership.

      Information Required in the BOI Report

      Entities must provide:

      • Full name of each beneficial owner
      • Date of birth
      • Address (residential or business)
      • Government-issued ID number (e.g., passport, tax ID)
      • Details of ownership interest or control over the entity

      BOI Report Due Date

      • For existing entities: Due by December 31, 2024 (varies by jurisdiction).
      • For new entities (formed in 2024 or later): Filing is required within 30 days of registration.
      • Updates/Changes: Any changes in beneficial ownership must be reported within 30 days of the change.

      With the February 18, 2025, decision by the U.S. District Court for the Eastern District of Texas in Smith, et al. v. U.S. Department of the Treasury, et al., 6:24-cv-00336 (E.D. Tex.), beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are once again back in effect. However, because the Department of the Treasury recognizes that reporting companies may need additional time to comply with their BOI reporting obligations, FinCEN is generally extending the deadline 30 calendar days from February 19, 2025, for most companies.

      Tax regime for new residents – 2024 version

      Italy’s “Regime Impatriati” is a special tax incentive designed to attract professionals to relocate to Italy by offering significant tax benefits. Recent legislative changes have modified the requirements and benefits of this regime, effective from January 1, 2024. Here’s an overview of how the regime functions starting in 2025:

      Eligibility Criteria:

      1. Non-Residency Requirement: Individuals must not have been tax residents in Italy for at least three tax periods prior to the year they become Italian tax residents.
      2. Employment in Italy: The individual must be employed or self-employed in Italy.
      3. Duration of Stay: The individual must commit to residing in Italy for at least four years.

      Tax Benefits:

      • Income Tax Reduction: Eligible individuals can benefit from a 50% reduction in taxable employment or self-employment income, with a maximum cap of €600,000 per year.
      • Duration of Benefits: The tax benefit applies for the tax year in which the individual transfers their tax residency to Italy and extends for the following four years, totaling five years of tax incentives.

      Additional Considerations:

      • Highly Qualified Professionals: The regime is particularly aimed at highly qualified or specialized individuals, aligning with definitions similar to those for a Schengen Blue Card.
      • Inter-Company Transfers: The regime also applies to individuals transferring within the same corporate group, provided specific conditions are met.

      These changes aim to attract international talent and encourage the return of Italian citizens by offering substantial tax incentives.

      Tax Treatment of Expense Reimbursements for Professionals in Italy: 2025 Updates

      As of January 1, 2025, significant changes have been introduced regarding the tax treatment of expense reimbursements for professionals in Italy. These changes stem primarily from Legislative Decree No. 192/2024 and the 2025 Budget Law.

      Reimbursement of Itemized Expenses for Professionals

      Expenses incurred by professionals while carrying out an assignment, when reimbursed on an itemized basis by the client, no longer contribute to taxable self-employment income. As a result, these reimbursements:

      • Are no longer subject to withholding tax.
      • Are not subject to pension fund contributions.
      • Remain subject to VAT, as they do not qualify as expenses incurred on behalf of the client under Article 15 of Presidential Decree No. 633/1972.

      To benefit from this tax treatment, expenses must be:

      • Incurred in the interest of the client.
      • Documented in a detailed and itemized manner.
      • Paid using traceable payment methods, such as credit cards, bank transfers, or other electronic payment systems.

      If the client fails to reimburse the professional, these expenses may still be deductible under specific conditions, such as in cases of client insolvency or the expiration of the credit claim.

      Mandatory Use of Traceable Payments

      The 2025 Budget Law has introduced a mandatory requirement to use traceable payment methods for the deductibility of travel and representation expenses. This requirement applies to professionals, employees, and businesses. Affected expenses include:

      • Hotel accommodations.
      • Meals and beverages.
      • Travel and transportation expenses, including taxi services and car rentals with drivers.

      If these expenses are not paid using traceable methods, they will not be deductible from taxable income. For employees, reimbursements for such expenses will become taxable for both income tax and social security purposes.

      Impact on Professionals Under the Flat-Rate Regime

      The new regulations do not appear to apply to professionals operating under the flat-rate tax regime, as the changes specifically affect Article 54 of the Italian Income Tax Code (TUIR), which governs self-employment income determination under the ordinary and simplified regimes.

      Conclusion

      These new provisions aim to enhance financial transparency and combat tax evasion by enforcing the use of traceable payment methods for the professional and business expenses.

      Special Italian TAX regime for University Professors and Researchers : just 10% is taxed

      The special Tax Regime ( art. 44 L. n 78/10 ) refers  to the income from employment (or self-employment) produced in Italy for University teaching and research activities. For such income, just its 10% is taxable.

      The regime applies from the tax period when  the teacher or researcher becomes fiscally resident in Italy, with these further conditions for access:

      • Be in possession of a university degree or equivalent;

      • Have not been occasionally resident abroad;

      • Have carried out documented research or teaching abroad at public / private research centers or universities for at least 2 continuous years;

      • Carry out teaching or research activities in Italy;

      • Acquire tax residence in the Italian territory.

      Duration of the regime : year of return + 5 more years . In the case of more children and / or property purchases , it can reach up to 13years

      In the event that the person moves his residence in Italy, but continues to carry out research or teaching activities abroad, the benefit is limited to the  income received in Italy as a teacher or researcher. Foreign income will thus  ordinarily be subject to Italian taxation, with a  tax credit for taxes paid abroad . ( Article 165 DPR 917/86.)

      Please do not hesitate to contact us for any further details.

      No special Tax regime for those who return in Italy to perform the same Job

      For Taxpayers who return in Italy after a period abroad , there is no tax benefit in the presence of the same contract, same job and with the same employer. This was clarified by the Agenzia delle Entrate  with the response to ruling no. 42 of 18 January 2021.

      If however the impatriate assumes a different corporate role than the original one, with a new contract that does not constitute a mere  the continuation of the previous work, the benefits will be granted.

      Special attention should thus be paid for those contract terms  that could indicate a mere prosecution of the previous Job  , as :

      – recognition of seniority from the date of first hiring;

      – the absence of the trial period;

      – clauses aimed at not paying the accrued thirteenth (and possibly fourteenth) accrued monthly salaries .

      We are as usual here for any further assistance .