Tax residence · Impatriate regime · Flat tax for new residents
Italy offers some of the most generous tax regimes in Europe to people who come to live here — but most of their conditions are fixed on the day you become resident, and some can no longer be chosen afterwards. We assess your position before the move: when you will become resident, which regime fits your income, and what has to be documented from day one.
Video call or at our office in Erba (Como) · In English or Italian
Who usually calls us
A new role with an Italian company, or a transfer within your group. The impatriate regime can halve the employment income on which Italian income tax is calculated — if the years spent abroad and your qualifications are counted and documented correctly.
Investments, dividends, rental income or a business abroad. The flat tax for new residents replaces Italian income tax on foreign income with a fixed annual amount, and removes foreign-asset reporting. Whether it pays depends on your numbers and on the year you move.
The rules are the same for Italian and foreign nationals, but the count of years abroad is where returning Italians most often go wrong — especially when coming back to the same employer or group they worked for before leaving.
Step one: becoming resident
None of the regimes below applies without a real, documented transfer of tax residence. Since 2024 the test has been rewritten (D.Lgs. 209/2023), and it is broader than many people expect.
You are Italian tax resident if, for most of the tax year, you have in Italy your habitual abode, your domicile — now defined as the place where your personal and family relationships are mainly centred — or simply your physical presence. Registration with the municipal population register (anagrafe) creates a presumption of residence, which can be rebutted.
The tax year is the calendar year, and "most of it" means at least 183 days (184 in a leap year). Days need not be consecutive, and any fraction of a day counts as a whole day. Working remotely from Italy for more than half the year makes you resident, even if your employer is abroad.
Residence is assessed year by year, for the whole year: Italian domestic law has no split-year rule. Some double tax treaties allocate the year of the move differently, and where two countries both treat you as resident the treaty tie-breaker decides. The date you arrive therefore fixes when Italian taxation — and any special regime — begins.
Regime one · employment and professional income
For people who move their tax residence to Italy from 2024 (art. 5 D.Lgs. 209/2023). Employment income and self-employed professional income earned in Italy is taxed on only 50% of its amount, up to €600,000 of income a year.
People who moved to Italy by 31 December 2023 remain under the previous regime (art. 16 D.Lgs. 147/2015), with different rules; the two cannot be swapped. University lecturers and researchers have a separate, wider regime that excludes 90% of their earnings from taxable income. Our Italian article Regime impatriati 2026 covers the details.
Regime two · foreign income
Under art. 24-bis of the Italian income tax code (TUIR, renumbered from 2027), Italian income tax on foreign-source income is replaced by a fixed annual substitute tax, whatever the amount of that income. Income produced in Italy is taxed under the ordinary rules.
The flat tax cannot be combined with the researchers' regime or with the impatriate regime for moves up to 2023, and for people who move from tax year 2027 it can no longer be combined with the current impatriate regime either (D.L. 38/2026). If you have both an Italian salary and significant foreign income, the order of decisions matters: regime first, date of the move second.
Regime three · foreign pensions
Recipients of pensions paid from abroad who move to a municipality of no more than 30,000 inhabitants in Sicily, Calabria, Sardinia, Campania, Basilicata, Abruzzo, Molise or Apulia, or in certain municipalities of central Italy hit by earthquakes, can opt for a 7% substitute tax on all their foreign income (art. 24-ter TUIR). It requires no Italian tax residence in the previous five years and a move from a country with an administrative cooperation agreement with Italy, and lasts for the year of the move and the following nine.
It does not apply to Lake Como, Milan or anywhere else in Lombardy. If you are retiring to our area, the relevant options are the ordinary rules or, with substantial foreign income, the flat tax for new residents.
Once you are resident
How we help
Free. Where you live now, your income and assets, your family, your timing. We tell you which regimes are realistically open to you.
Video call or officeResidence test and treaty position, years abroad, the numbers for each regime, the best date to move and the evidence to collect. You receive a written proposal for our work before we start.
Before the moveWe prepare the employer request for the impatriate regime or the ruling request for the flat tax, with the file on your past residence and qualifications.
In the year of the moveYour first Italian tax return (modello Redditi PF), substitute tax payments, foreign-asset reporting and the checks that keep the regime in place year after year.
Every yearTo be clear
The firm
Tentori TLS – Tax & Legal Solutions is a tax and corporate advisory firm based in Erba, between Lake Como and Milan. We work across Lombardy and Italy, in Italian and English, with individuals, entrepreneurs and their companies.
The best time to decide your Italian tax regime is before the removal van arrives.
You work directly with Manuel Tentori, Managing Partner. When your move also involves a company or a family holding, we look at it together — see holding companies in Italy.
Frequently asked questions
You are resident for an Italian tax year, which is the calendar year, if for most of it — at least 183 days, 184 in a leap year, with fractions of a day counted as whole days — you have in Italy your habitual abode, your domicile (the place where your personal and family relationships are mainly centred) or simply your physical presence. Registration with an Italian municipal population register (anagrafe) also creates a presumption of residence, which can be rebutted. The criteria are alternative: meeting one is enough.
Usually not, provided you do not meet any of the criteria — presence, habitual abode, domicile or registration — for most of that year: you then become resident from the following 1 January. Italian domestic law does not split the tax year, so you are resident or non-resident for the whole of it, although some double tax treaties allocate the year of the move differently. This is why the date of arrival is a planning decision: it fixes when Italian taxation starts and from which year the regimes for new residents run.
The flat tax cannot be combined with the regime for researchers and lecturers, nor with the impatriate regime that applied to moves up to 2023. D.L. 38/2026 extended the ban to the current impatriate regime for people who move to Italy from tax year 2027. For anyone with significant foreign investment income and an Italian employment package, the choice between the two regimes has to be made before the date of the move is fixed.
The wording of the law refers to a favourable ruling (interpello) from the Italian Revenue Agency, requested by the filing deadline of the tax return for the year of the move. The Agency's own guidance describes the ruling as optional and allows the option to be made directly in the tax return for the year of the move or the following year. With amounts this large and a horizon of up to 15 years, we generally recommend filing the ruling request with a complete file on your past residence.
Yes, under the ordinary rules: Italian residents report foreign investments and assets in section RW of the tax return and pay IVIE on real estate held abroad and IVAFE on financial assets held abroad. Those who opt for the flat tax for new residents, and the family members included in the option, are exempt from RW reporting and from IVIE and IVAFE for the years in which the option is valid.
The first step
Tell us where you live now, what you earn and own, and when you are thinking of moving. You leave with a straight answer: which regimes are open to you, what the timing means, and whether it makes sense to work together.
Choose a day and time
The calendar is loading. If it does not appear, book from the dedicated page or write to us: we will propose three times within one working day.
Open the full-page calendarPrefer the full page? Book on /en/book/ · Confirmation and video call link by e-mail
Further reading (in Italian)