Italy cross-border tax: residence, moving in, leaving, non-residents and withholding (2026)

General reference only. This skill is general tax reference material for AI-assisted work. It has not been reviewed for any specific person's facts. Do not rely on it to file, pay or take a tax position without review by a qualified Italian professional (commercialista).

This skill is the hub for what changes when a person or a company crosses Italy's border. It summarises the rules and links to the detailed skills in this pack rather than repeating them. The tax year is the calendar year. The authority is the Agenzia delle Entrate. Currency is the euro.

Which law applies in 2026. A new income tax code, the Testo unico delle imposte sui redditi approved by D.Lgs. 19 June 2026 n. 117, came into force on 4 July 2026 but applies only from 1 January 2027 (its art. 377, "Decorrenza"). For 2026 the old TUIR (D.P.R. 917/1986) still applies, so this skill cites the old article numbers, read on Normattiva as in force on 30 June 2026. From 2027 the article numbers change. Normattiva's "current" view may already show some old TUIR articles as repealed: that is the 2027 change, not a 2026 one.

Who this applies to

Individuals: the residence test (TUIR art. 2, from 2024)

D.Lgs. 209/2023 rewrote art. 2 comma 2 with effect from 1 January 2024. A person is Italian resident for income tax if, for most of the tax year (more than half), counting part days as well, they have any one of these in Italy:

• residence in the civil-law sense (Civil Code art. 43, the place of habitual abode);
• domicile, which now means "the place where the person's personal and family relations mainly develop" (no longer the centre of business and economic interests);
• physical presence in Italy.

Any one test is enough. A presence count above half the year, with part days counted, makes the person resident even with no home or family in Italy. For 2026 (365 days) that means 183 days or more.

Registry presumption. A person registered in the Italian population register (anagrafe) for most of the tax year is presumed resident, but this is now rebuttable ("salvo prova contraria"). Before 2024 registration was effectively conclusive.

Citizens who move to a state not on the white list. Italian citizens removed from the register who move to a state or territory not on the Ministry's white list are presumed still resident unless they prove otherwise (art. 2 comma 2-bis).

No split year in domestic law. Residence is decided for the whole tax year: a person is resident or non-resident for all of 2026. Someone who arrives on 1 July 2026 has fewer than 183 days and is non-resident for 2026 under domestic law (unless registered or domiciled in Italy for most of the year). Someone who leaves on 1 August has more than half the year in Italy and stays resident for the whole of 2026, taxed on worldwide income. Some treaties allow a split year; check the treaty.

AIRE (registry of Italians resident abroad)

An Italian citizen who moves abroad must declare the move to the Italian consulate for the new area within 90 days of arrival (L. 470/1988 art. 6 comma 1). A change of address abroad is declared within 90 days as well (comma 3). The registry presumption above runs on the municipal population register, so the register entry matters. But AIRE registration alone does not make a person non-resident: the presence, domicile and civil-law residence tests still apply.

Companies (TUIR art. 73 comma 3, from 2024)

A company or entity is Italian resident if, for most of the tax period, it has in Italy any of:

• its registered office (sede legale);
• its place of effective management (sede di direzione effettiva): the continuous and coordinated taking of strategic decisions about the company as a whole;
• its day-to-day management (gestione ordinaria in via principale): the continuous and coordinated carrying out of current management acts.

Foreign companies that control an Italian company are presumed resident (rebuttable) if they are themselves controlled from Italy or if most of their board are Italian residents (art. 73 comma 5-bis).

Rates, bands and thresholds

Item	Figure	Tax year	Source
IRPEF bands (residents and non-residents alike): up to EUR 28,000	23%	2026	https://www.agenziaentrate.gov.it/portale/imposta-sul-reddito-delle-persone-fisiche-irpef-/aliquote-e-calcolo-dell-irpef
IRPEF, EUR 28,001 to 50,000	33% (35% in 2024 and 2025)	2026	same
IRPEF, above EUR 50,000	43%; tax on the first 50,000 is EUR 13,700	2026	same
IRES (corporate income tax)	24%	2026	https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1986-12-22;917~art77!vig=2026-06-30
Impatriati regime (arrivals from 2024): share of qualifying income taxed	50% (40% with a minor child)	2026	https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:2023-12-27;209~art5!vig=2026-06-30
Impatriati yearly cap on qualifying income	EUR 600,000	2026	same
Flat tax on foreign income (art. 24-bis), moves from 1 January 2026	EUR 300,000 a year, plus EUR 50,000 per family member added (both raised by L. 199/2025, in force 1 January 2026; previously EUR 200,000 and EUR 25,000)	2026	https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1986-12-22;917~art24bis!vig=2026-06-30 and https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:legge:2025-12-30;199 (art. 1 commi 25 and 26)
Pensioners' option (art. 24-ter): substitute tax on all foreign income	7%	2026	https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1986-12-22;917~art24ter!vig=2026-06-30
Exit tax (art. 166)	No separate rate: the gain is taxed at the taxpayer's normal rate (IRES 24% for a company). For sole traders and partnerships, comma 13 applies the separate-taxation rules of TUIR art. 17 comma 1 letters g) and l)	2026	https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1986-12-22;917~art166!vig=2026-06-30
Exit tax instalments (move to an EU or listed EEA state)	5 equal annual instalments, interest on instalments after the first	2026	same
Dividends paid to non-residents (final withholding)	26%	2026	https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legge:2014-04-24;66~art3!vig=2026-06-30 (sets 26% for art. 44 capital income); https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1973-09-29;600~art27!vig=2026-06-30
Dividends paid to companies subject to corporate tax in an EU or listed EEA state	1.20%	2026	D.P.R. 600/1973 art. 27 comma 3-ter, same URL
Dividends to an EU parent company holding at least 10% of the capital directly and without interruption for at least one year (Parent-Subsidiary Directive)	Exempt: no withholding if the payer has the documents by payment date, otherwise full refund	2026	D.P.R. 600/1973 art. 27-bis commi 1 to 3 (text shows 20%), https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1973-09-29;600~art27bis!vig=2026-06-30 ; the 20% is reduced to 10% for profits distributed from 1 January 2009 by D.Lgs. 49/2007 art. 2 comma 2, https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:2007-02-06;49~art2!vig=2026-06-30
Dividends to EU and listed EEA pension funds	11%	2026	D.P.R. 600/1973 art. 27 comma 3, same URL
Interest and other capital income paid to non-residents (final withholding)	26% (not for Italian government bonds and bonds of white-list states, excluded by D.L. 66/2014 art. 3 comma 2)	2026	D.L. 66/2014 art. 3 comma 1 (URL above); https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1973-09-29;600~art26!vig=2026-06-30
Interest and royalties paid to an associated EU company (25% of voting rights, held without interruption for at least one year)	Exempt	2026	https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1973-09-29;600~art26quater!vig=2026-06-30
Fees for self-employed work done in Italy, paid to non-residents (final withholding)	30%	2026	https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1973-09-29;600~art25!vig=2026-06-30
Royalties (intellectual property, patents, trade marks, know-how) paid to non-residents	30% of the taxable part	2026	D.P.R. 600/1973 art. 25, same URL
Rent for industrial, commercial or scientific equipment located in Italy, paid to non-residents	30%	2026	D.P.R. 600/1973 art. 25, same URL

Treaty rates replace these where the treaty gives a lower rate and the paperwork is in place. Dividend withholding at 26% can be partly refunded to non-resident shareholders (up to eleven twenty-sixths of the withholding) if they prove tax paid on the same dividends abroad (art. 27 comma 3).

The taxable base

Residents: worldwide income. A resident individual or company is taxed on income from anywhere. There is no remittance basis. The nearest thing is the art. 24-bis flat tax, which replaces tax on foreign income with a fixed yearly amount.

Non-residents: Italian-source income only (TUIR art. 23). The main items treated as produced in Italy:

• income from land and buildings in Italy;
• capital income paid by the Italian State, Italian residents or Italian permanent establishments (but not interest on bank and postal deposits and current accounts);
• employment income for work done in Italy;
• self-employment income from activities carried on in Italy;
• business income through an Italian permanent establishment;
• other income from activities in Italy or assets in Italy, and gains on shares in Italian resident companies (gains on listed shares are excluded);
• gains on shares in foreign companies whose value comes mainly (more than half, at any time in the 365 days before the sale) from Italian real estate (comma 1-bis; not for shares traded on regulated markets).

Pensions, end-of-service payments and royalties paid by Italian payers are Italian-source whatever the place of work (comma 2).

How a non-resident is taxed (TUIR art. 24). The normal IRPEF bands apply, but only a few deductions are allowed and no family allowances are given. A non-resident who earns at least 75% of total income in Italy and lives in a state with adequate information exchange is taxed like a resident, with full allowances, provided they get no similar relief at home (art. 24 comma 3-bis).

Inbound regimes in one paragraph each. Full rules, codes and edge cases are in the it-impatriati skill.

• Impatriati (D.Lgs. 209/2023 art. 5, arrivals from 2024). Employment and professional income produced in Italy counts at 50% (40% with a minor child resident in Italy), up to EUR 600,000 a year, for the year of the move and the next four. Conditions: not resident in the three prior years (six or seven if staying with the same employer or group), commitment to stay at least four years (or the benefit is clawed back with interest), work done in Italy for most of the year, and high qualification under D.Lgs. 108/2012 and 206/2007 (or applied AI research). Business income and investment income are not covered.
• Flat tax for new residents (art. 24-bis). A fixed EUR 300,000 a year (moves from 1 January 2026; EUR 200,000 for moves after D.L. 113/2024 came into force on 10 August 2024; EUR 100,000 before that) replaces IRPEF on foreign income. Each family member added pays EUR 50,000 a year for moves from 1 January 2026 (EUR 25,000 before). The person must not have been resident in nine of the previous ten years. A favourable ruling (interpello) is needed first. It lasts up to 15 years. Gains on qualifying shareholdings in the first five years are still taxed normally.
• Pensioners' option (art. 24-ter). Foreign-pension holders who move to a town of up to 30,000 inhabitants in certain southern regions (or listed earthquake towns), and who were not resident in the five previous years and move from a country with an administrative cooperation agreement, can pay 7% on all foreign income for the year of the move and the next nine.

Leaving: the exit tax (TUIR art. 166). It applies to "soggetti che esercitano imprese commerciali": companies, and also individuals and partnerships that carry on a commercial business. The charge arises when such a taxpayer moves tax residence abroad, transfers assets to an exempt foreign branch, moves a whole Italian permanent establishment abroad, or is merged or demerged into a foreign company. The taxable amount is the difference between the market value and the tax cost of the assets and liabilities that do not stay in an Italian permanent establishment, valued at arm's length and including goodwill. Losses up to the last resident period reduce the gain; where no Italian permanent establishment remains, without the usual 80% limit (comma 6). Tax-suspended reserves are taxed too (comma 5).

Individuals who are not in business. Art. 166 does not reach an employee or a private investor. We found no other general exit charge on the shares or other assets of an individual who leaves Italy in the 2026 TUIR. The person simply becomes non-resident and is then taxed on Italian-source income only (including, under art. 23, gains on unlisted Italian shares, subject to any treaty).

Deadlines and filing

What	When	Source
AIRE declaration after moving abroad (Italian citizens)	Within 90 days of arrival, to the consulate	L. 470/1988 art. 6, https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:legge:1988-10-27;470~art6!vig=2026-06-30
Individual income tax return (Redditi PF), residents and non-residents	Online between 15 April and 31 October of the following year (31 October 2027 for 2026 income)	D.P.R. 322/1998 art. 2 comma 1, https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1998-07-22;322~art2!vig=2026-06-30
Company return (Redditi SC), including the exit-tax period	By the last day of the tenth month after the period end (31 October 2027 for a calendar 2026 period)	D.P.R. 322/1998 art. 2 comma 2, same URL
Flat tax ruling request (art. 24-bis)	By the return deadline for the year of the move; the option then applies from that year	TUIR art. 24-bis comma 3
Flat tax and 7% pensioners' tax payment	One payment by the due date for the IRPEF balance	TUIR art. 24-bis comma 2; art. 24-ter
Exit tax: when the gain is fixed	At the end of the last tax period of Italian residence (for a residence move)	TUIR art. 166 comma 7
Exit tax: payment	With the tax for that last period, or by option in five equal annual instalments if the move is to an EU state or a listed EEA state with a recovery-assistance agreement; guarantees may be required	TUIR art. 166 commi 9 to 11

Non-resident returns. A non-resident with Italian income that was not taxed at source by final withholding (for example rent, or employment income from a non-Italian payer) files Redditi PF on the same timetable. Final withholding (dividends, interest, fees, royalties) usually ends the obligation.

Foreign assets (quadro RW). Resident individuals, non-commercial entities and simple partnerships (not companies) report foreign investments, foreign financial assets and crypto-assets each year in the RW section of the return (D.L. 167/1990 art. 4). People under the art. 24-bis flat tax are exempt from this reporting.

Withholding agents. The Italian payer withholds at the moment of payment, pays the tax over and reports the payments in its annual withholding agent return. See italy-payroll for the payroll side.

Exit tax instalments end early if the taxpayer moves on from the EU or EEA state to a state outside the list, sells the assets whose value made up the gain, goes bankrupt or is wound up, or misses an instalment and does not put it right within 5 months; the remaining tax is then due at the next instalment date (art. 166 comma 12).

Penalties and interest

Failure	Penalty	Source
No income tax return filed	120% of the tax due, minimum EUR 250; EUR 250 to 1,000 if no tax is due	D.Lgs. 471/1997 art. 1 comma 1, https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:1997-12-18;471~art1!vig=2026-06-30
Return filed more than 90 days late (before any audit)	The late-payment penalty below, tripled	art. 1 comma 1-bis, same URL
Return understates income or tax	70% of the extra tax, minimum EUR 150	art. 1 comma 2, same URL
Late or missing payment	25% of the unpaid amount; halved if paid within 90 days; reduced further for delays up to 15 days	D.Lgs. 471/1997 art. 13, https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:1997-12-18;471~art13!vig=2026-06-30
Withholding agent fails to withhold	20% of the amount not withheld	D.Lgs. 471/1997 art. 14, https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:1997-12-18;471~art14!vig=2026-06-30
Foreign assets not reported in RW	3% to 15% of the amounts not declared; 6% to 30% for assets in listed tax havens; EUR 258 if filed within 90 days	D.L. 167/1990 art. 5 comma 2, https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legge:1990-06-28;167~art5!vig=2026-06-30

These are the rates in the texts in force on 30 June 2026. Voluntary correction (ravvedimento operoso, D.Lgs. 472/1997 art. 13) reduces them. Late-payment interest is charged on top; the rate is set by decree and is not given here.

The impatriati regime has its own clawback: if the worker does not keep Italian residence for at least four years, the benefit is recovered with interest (D.Lgs. 209/2023 art. 5 comma 3). The flat tax ends if the yearly amount is not paid in full and on time (art. 24-bis comma 4).

Cross-border points

Treaty tie-breaker. Where a person is resident in Italy under art. 2 and in another state under its law, the treaty's residence article decides (in the OECD model: permanent home, then centre of vital interests, then habitual abode, then nationality). The new domestic tests (part days count, domicile as personal and family relations) make dual residence more likely in the year of a move. Read the specific treaty.

Foreign tax credit, not exemption (TUIR art. 165). Italy relieves double tax by a credit. Foreign tax paid "a titolo definitivo" (finally, not as a refundable advance) is credited against Italian net tax, limited to the Italian tax on that foreign income: Italian tax times foreign income divided by total income (net of losses brought forward). The limit is applied country by country (comma 3). The credit is claimed in the return for the year the income belongs to, if the foreign tax is final before filing; otherwise in a later return (commi 4, 5 and 7). No credit if the return is not filed or the foreign income is left out of it (comma 8). For businesses, excess foreign tax can be carried back and forward for eight years (comma 6).

EU social security. For moves within the EU and EEA, Regulation (EC) 883/2004 decides which single country's social security applies, usually the country where the work is done; posted workers can stay in the home system with an A1 certificate. Italian social contributions are covered in it-inps-contributions and italy-payroll.

Pointers.

• Full impatriati, flat tax and pensioners' regime rules: it-impatriati.
• IRPEF computation, deductions, regional and municipal surcharges: it-income-tax.
• Employer withholding and payroll for inbound and outbound staff: italy-payroll.
• Related-party pricing and the arm's-length value used in the exit tax: italy-transfer-pricing.
• Crypto held by people who move in or out: italy-crypto-tax.
• For IRES itself (rate, base, losses, dividends) see it-ires-corporate-tax; this skill covers only the exit tax and outbound withholding.

Worked examples

Example 1: an engineer moves to Milan under the impatriati regime

Facts. Anna, a software engineer with a qualifying degree, moves from London to Milan on 10 January 2026 to join an Italian company that is not part of her former employer's group. She was not Italian resident in 2023, 2024 or 2025. She has no children. Her 2026 salary is EUR 120,000, all for work done in Italy.

Residence. She is present and registered in Italy for most of 2026, so she is resident for the whole year under art. 2.

Regime. She meets the art. 5 conditions (three years abroad with a new employer, high qualification, work in Italy for most of the year, a commitment to stay four years). Her salary is below the EUR 600,000 cap, so 50% counts: EUR 60,000.

Tax (2026 bands, before deductions, tax credits and regional and municipal surcharges):

• first EUR 28,000 at 23% = EUR 6,440
• next EUR 22,000 at 33% = EUR 7,260
• last EUR 10,000 at 43% = EUR 4,300
• gross IRPEF = EUR 18,000

Without the regime, gross IRPEF on EUR 120,000 would be EUR 13,700 + 43% of EUR 70,000 = EUR 43,800. The regime saves EUR 25,800 of gross IRPEF in 2026. If she leaves Italy before four years, the saving is clawed back with interest.

name: Impatriato, salary EUR 120,000, 50% taxable (2026 IRPEF bands)
inputs:
  salary: 120000
  share_taxable: 0.50
steps:
  - taxable: salary * share_taxable
  - band_23: min(taxable, 28000) * 0.23
  - band_33: (min(taxable, 50000) - 28000) * 0.33
  - band_43: max(taxable - 50000, 0) * 0.43
  - irpef_regime: band_23 + band_33 + band_43
  - irpef_normal: 28000 * 0.23 + 22000 * 0.33 + (salary - 50000) * 0.43
  - saving: irpef_normal - irpef_regime
expected:
  taxable: 60000.00
  irpef_regime: 18000.00
  irpef_normal: 43800.00
  saving: 25800.00

Example 2: an Italian company moves its tax residence to Germany

Facts. Alfa S.r.l., a calendar-year trading company, moves its place of effective management and registered office to Germany during 2026 and keeps no permanent establishment in Italy. At the end of its last Italian tax period, the market value of its assets and liabilities (including goodwill) is EUR 2,500,000 and their tax cost is EUR 1,300,000. It has EUR 200,000 of tax losses brought forward and no other income in the period.

Exit gain. EUR 2,500,000 - EUR 1,300,000 = EUR 1,200,000 (art. 166 comma 3(a)).

Losses. No Italian permanent establishment remains, so the EUR 200,000 of losses reduce the gain in full, without the 80% limit (comma 6). Taxable exit gain: EUR 1,000,000.

Tax. IRES at 24% = EUR 240,000.

Payment. Germany is an EU state, so Alfa can opt to pay in five equal annual instalments of EUR 48,000, with interest on the four later instalments (commi 9 and 11). The option covers the whole exit tax (comma 10). If Alfa later moves to a non-EU, non-listed state, the balance falls due at the next instalment date (comma 12). Tax-suspended reserves, IRAP and the interest amount are not computed here.

name: Company exit tax on move to Germany, IRES 24%, five instalments (2026)
inputs:
  market_value: 2500000
  tax_cost: 1300000
  losses_bf: 200000
  ires_rate: 0.24
  instalments: 5
steps:
  - gain: market_value - tax_cost
  - taxable_gain: gain - min(losses_bf, gain)
  - exit_tax: taxable_gain * ires_rate
  - instalment: exit_tax / instalments
expected:
  gain: 1200000.00
  taxable_gain: 1000000.00
  exit_tax: 240000.00
  instalment: 48000.00

A short outbound withholding check: an Italian company pays a non-resident consultant EUR 10,000 for work done in Italy. With no treaty relief claimed, it withholds 30%, EUR 3,000, as a final tax (D.P.R. 600/1973 art. 25). If the work is done abroad, there is no Italian withholding.

Ask the client first

1. On which date did you arrive in or leave Italy, and how many days (counting part days) were you in Italy in 2026? Were you on the population register or AIRE, and for how long?
2. Where do your spouse or partner and children live? Under the 2024 rules, that decides domicile.
3. Are you an Italian citizen, and if you left, which country did you move to? (A move to a non-white-listed state keeps the presumption of residence.)
4. For a move in: in how many of the last ten years were you Italian resident, will you work for the same employer or group as before, and what is your qualification? This decides impatriati, flat tax or neither.
5. For a company or a business owner leaving: do you carry on a commercial business, will a permanent establishment stay in Italy, what are the market values and tax costs of the assets, and which state are you moving to (EU or listed EEA for instalments)?
6. What Italian income will you have after leaving (rent, salary, dividends, gains on Italian shares), and does a treaty apply?

Sources

All read on 2026-10-22. Normattiva texts are the versions in force on 30 June 2026 unless stated.

• TUIR art. 2 (individual residence): https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1986-12-22;917~art2!vig=2026-06-30
• TUIR art. 23 (Italian-source income of non-residents): https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1986-12-22;917~art23!vig=2026-06-30
• TUIR art. 24 (tax of non-residents, 75% rule): https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1986-12-22;917~art24!vig=2026-06-30
• TUIR art. 24-bis (flat tax): https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1986-12-22;917~art24bis!vig=2026-06-30
• TUIR art. 24-ter (pensioners' 7% option): https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1986-12-22;917~art24ter!vig=2026-06-30
• TUIR art. 54-octies (royalties reduced by 25% for expenses): https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1986-12-22;917~art54octies!vig=2026-06-30
• TUIR art. 73 (company residence): https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1986-12-22;917~art73!vig=2026-06-30
• TUIR art. 77 (IRES 24%): https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1986-12-22;917~art77!vig=2026-06-30
• TUIR art. 165 (foreign tax credit): https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1986-12-22;917~art165!vig=2026-06-30
• TUIR art. 166 (exit tax): https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1986-12-22;917~art166!vig=2026-06-30
• D.Lgs. 117/2026 (new TUIR, applies from 1 January 2027 under its art. 377), read as in force on 22 October 2026: https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:2026-06-19;117
• D.Lgs. 209/2023 art. 5 (impatriati): https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:2023-12-27;209~art5!vig=2026-06-30
• L. 199/2025 art. 1 commi 25 and 26 (flat tax raised to EUR 300,000): https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:legge:2025-12-30;199
• D.P.R. 600/1973 art. 25 (fees and royalties to non-residents): https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1973-09-29;600~art25!vig=2026-06-30
• D.P.R. 600/1973 art. 26 (interest): https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1973-09-29;600~art26!vig=2026-06-30
• D.P.R. 600/1973 art. 26-quater (EU interest and royalties exemption): https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1973-09-29;600~art26quater!vig=2026-06-30
• D.P.R. 600/1973 art. 27 (dividends): https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1973-09-29;600~art27!vig=2026-06-30
• D.P.R. 600/1973 art. 27-bis (EU parent-subsidiary refund or exemption): https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1973-09-29;600~art27bis!vig=2026-06-30
• D.Lgs. 49/2007 art. 2 comma 2 (art. 27-bis threshold 10% for profits distributed from 1 January 2009; Normattiva shows this comma repealed from 2027 by D.Lgs. 33/2025 as amended by D.L. 200/2025): https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:2007-02-06;49~art2!vig=2026-06-30
• D.L. 66/2014 art. 3 (26% rate on capital income): https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legge:2014-04-24;66~art3!vig=2026-06-30
• D.P.R. 322/1998 art. 2 (return deadlines): https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1998-07-22;322~art2!vig=2026-06-30
• L. 470/1988 art. 6 (AIRE): https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:legge:1988-10-27;470~art6!vig=2026-06-30
• D.Lgs. 471/1997 art. 1, 13 and 14 (penalties): https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:1997-12-18;471~art1!vig=2026-06-30 , https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:1997-12-18;471~art13!vig=2026-06-30 , https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:1997-12-18;471~art14!vig=2026-06-30
• D.L. 167/1990 art. 5 (RW penalties): https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legge:1990-06-28;167~art5!vig=2026-06-30
• Agenzia delle Entrate, IRPEF rates and the 2026 change to 33%: https://www.agenziaentrate.gov.it/portale/imposta-sul-reddito-delle-persone-fisiche-irpef-/aliquote-e-calcolo-dell-irpef

Not yet confirmed: the taxable part of royalties paid to non-resident companies (TUIR art. 54-octies reduces royalties by 25% for individual authors and inventors, which would give 22.5% of the gross, but we did not confirm the same base for companies); the late-payment interest rate and the interest rate on exit tax instalments (D.Lgs. 241/1997 art. 20); any AIRE non-registration penalty; and the Regulation (EC) 883/2004 text, which we could not fetch from EUR-Lex today.

Contributed by Ryan Duguid.