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Categoria: Tax Regimes

Expats, Impatriati, New residents, Tax Regimes

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

Apr 28, 2026 di antonio malavasi 0 Commenti

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.

Expats, Impatriati, Tax Regimes

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

Apr 24, 2026 di antonio malavasi 0 Commenti

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.

Expats, Impatriati, Tax Regimes

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

Apr 9, 2026 di antonio malavasi 0 Commenti

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.

Expats, Impatriati, Tax Regimes

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

Apr 8, 2026 di antonio malavasi 0 Commenti

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.
Expats, New residents, Tax Regimes

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

Apr 8, 2026 di antonio malavasi 0 Commenti







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.

7% retirees, Expats, Tax Regimes

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

Mar 2, 2026 di antonio malavasi 0 Commenti

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.

Corporate Taxation, Expats, Impatriati, Tax Regimes

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

Mar 1, 2026 di antonio malavasi 0 Commenti

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.

Expats, Forfettario, Impatriati, Tax Regimes

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

Feb 6, 2026 di antonio malavasi 0 Commenti

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 !

Expats, New residents, Tax Regimes

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

Dic 30, 2025 di antonio malavasi 0 Commenti

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.

Corporate Taxation, Expats, Impatriati, Tax Regimes

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

Ott 29, 2025 di antonio malavasi 0 Commenti

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.

Expats, Impatriati, Tax Regimes

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

Lug 16, 2025 di antonio malavasi 0 Commenti

🌍 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.

Expats, Forfettario, Tax Regimes

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

Apr 9, 2025 di antonio malavasi 0 Commenti

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 !

Tax Regimes, Uncategorized

Italy Tax system

Feb 12, 2025 di antonio malavasi 0 Commenti

Understanding Taxes in Italy: A Simple Guide

Italy has a complex tax system with different taxes at the national, regional, and local levels. If you live or work in Italy, it’s essential to understand how taxes work, what rates apply, and when you need to pay. Let’s break it down in an easy-to-understand way.

1. Main Types of Taxes in Italy

There are two major categories of taxes in Italy: direct taxes (on income and assets) and indirect taxes (on goods and services).

A. Direct Taxes (Taxes on Income and Business)

  1. IRPEF (Personal Income Tax)
    • Paid by individuals based on their earnings.
    • Uses a progressive system, meaning the more you earn, the higher your tax rate.
  2. IRES (Corporate Income Tax)
    • A flat tax of 24% paid by companies and businesses.
  3. IRAP (Regional Business Tax)
    • Paid by businesses and professionals.
    • The rate depends on the region but is typically around 3.9%.
  4. IMU (Property Tax)
    • Applied to properties (except for primary residences in most cases).
    • The rate varies by municipality.

B. Indirect Taxes (Taxes on Goods and Services)

  1. IVA (Value-Added Tax – VAT)
    • Applied to the sale of goods and services.
    • Standard rate: 22%
    • Reduced rates: 10% (e.g., food, hotels) and 4% – 5% (e.g., essential items).
  2. Other Indirect Taxes
    • Registration taxes, stamp duties, and real estate transaction fees.

2. Personal Income Tax Rates (IRPEF)

IRPEF is progressive, meaning higher incomes are taxed at higher rates:

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

There are also deductions and allowances that reduce the total amount of tax you owe.

3. How and When to Pay Taxes in Italy

Taxes are usually paid through withholding, advance payments, and direct declarations.

For Employees & Pensioners

  • Taxes are automatically deducted from salaries and pensions.
  • Employers and pension funds take care of payments.

For Freelancers & Self-Employed Workers

  • Must file a tax return and pay in advance based on the previous year’s income.
  • Payments are made in two installments:
    • First installment: June 30
    • Second installment: November 30

For Companies (IRES, IRAP)

  • Companies pay in advance, similar to personal income tax.
  • The final balance is settled the following year.

For VAT (IVA)

  • Businesses must collect VAT from customers and pay it to the tax authorities.
  • Payments are usually quarterly or monthly.

4. How to Pay Taxes

Taxes in Italy are paid through:

  • F24 Form (submitted online via banks or the Italian Tax Agency).
  • Direct debit payments (for recurring taxes).
  • Online banking and tax portals.

5. Tax Returns and Deadlines

  • Personal Tax Returns (Modello 730 or Modello Redditi PF):
    • Employees & pensioners: By September 30.
    • Freelancers & self-employed: By November 30.
  • Business Tax Returns:
    • Usually filed by April 30 for the previous year.

6. Additional Local Taxes

  • TARI (Waste Collection Tax) – Paid to local municipalities for garbage services.
  • Regional and Municipal Surcharges – Additional small taxes applied to IRPEF, varying by location.

Final Thoughts

Italy’s tax system may seem complicated, but understanding the basics can help you manage your payments effectively and avoid penalties. Whether you’re an employee, freelancer, or business owner, staying informed about your tax obligations is key.

Expats, New residents, Tax Regimes

Tax regime for new residents – 2024 version

Feb 7, 2025 di antonio malavasi 0 Commenti

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.

Expats, Tax Regimes

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

Apr 16, 2024 di antonio malavasi 0 Commenti

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.

Expats, Impatriati, Tax Regimes

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

Apr 16, 2024 di antonio malavasi 0 Commenti

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 .