Italy's tax regimes for people moving to Italy: impatriati workers, the flat tax on foreign income, and the pensioners' option

This Guide covers the three Italian income tax regimes for people who move their tax residence to Italy: the impatriati regime for workers (new rules of D.Lgs. 209/2023 art. 5 for arrivals from 2024, old rules of D.Lgs. 147/2015 art. 16 for earlier arrivals), the flat substitute tax on foreign income of TUIR art. 24-bis, and the substitute tax for foreign pensioners of TUIR art. 24-ter. Figures are for tax year 2026. Italy's tax year is the calendar year. The statutes were read on Normattiva as in force on 30 June 2026, because a new TUIR (D.Lgs. 117/2026) is already in force and Normattiva's current view shows these articles as repealed, but it applies only from 1 January 2027. Two sources carry another date: the old art. 16 was read as in force on 28 December 2023 (it still governs earlier arrivals), and the Redditi PF instructions are the 2026 edition, for 2025 income. Older flat tax amounts are shown from the versions of art. 24-bis in force when they applied.

Three regimes: which applies

Three regimes: which applies

Regime	Who it's for
Impatriati (worker regime)	Employees, people with income treated as employment, and self-employed professionals who move tax residence to Italy and work there. Arrivals from 2024 use D.Lgs. 209/2023 art. 5; people who moved registered residence by 31 December 2023 stay on D.Lgs. 147/2015 art. 16
Flat tax on foreign income (TUIR art. 24-bis)	Individuals who move tax residence to Italy, with no work requirement. The amount depends on when they moved (see Regime 2)
Pensioners' option (TUIR art. 24-ter)	People with foreign pensions who move to a small town in certain southern regions (see the section on it below Regime 2)

A person cannot combine the flat tax with the old impatriati regime (L. 232/2016 art. 1 comma 154, reported in the notes to art. 24-bis). For 2027 onwards the impatriati rules move into the new TUIR (D.Lgs. 117/2026, Capo XIV); this Guide does not cover that text.

Regime 1: Impatriati (D.Lgs 209/2023, from 2024)

Eligibility (reformed rules from 2024)

The new regime applies to people who move tax residence to Italy under TUIR art. 2 from the 2024 tax year ("a decorrere dal periodo d'imposta 2024", art. 5 comma 8). All conditions in art. 5 comma 1 must be met:

• Non-residency before the move. Not Italian tax resident in the three tax periods before the move. If the person works in Italy for the same employer they worked for abroad, or for a company of the same group, the minimum time abroad is six tax periods, or seven if they had worked in Italy for that employer or group before leaving (art. 5 comma 1(b)). Three tax periods is the rule only when the worker joins a new employer outside the group.
• Italian citizens and the years before 2024. For tax periods before the decree came into force, Italian citizens count as resident abroad if they were registered with AIRE or were resident in another State under a double tax treaty (art. 5 comma 6).
• Commitment to stay. The worker commits to keep Italian tax residence for the period in art. 5 comma 3. If tax residence is not kept for at least four years, the benefit is lost and what was used is recovered with interest (art. 5 comma 3).
• Work mainly in Italy. The work is done in Italy "per la maggior parte del periodo d'imposta" (for most of the tax period). The law gives no day count; a test of "more than 183 days" is not in the text.
• High qualification. The worker holds the "requisiti di elevata qualificazione o specializzazione" defined by D.Lgs. 108/2012 and D.Lgs. 206/2007, or has done research, including applied research, in artificial intelligence (art. 5 comma 1(d)). The law does not say "university degree"; which qualifications meet the two decrees is a question for the adviser.
• Previous use of the regime. Art. 5 has no rule barring someone who used the regime before. A "no prior benefit" condition is not in the text; see "When to refuse or refer".
• EU state aid limits. The regime applies within the EU de minimis regulations 1407/2013, 1408/2013 and 717/2014 (art. 5 comma 7).

Pre-2024 rules (for those who started before 1 Jan 2024 under the old regime):

• The old regime (D.Lgs. 147/2015 art. 16) was repealed from the decree's entry into force, but it still applies to people who moved their registered residence (residenza anagrafica) to Italy by 31 December 2023, and to sports contracts signed by that date (art. 5 comma 9).
• Its conditions were: not resident in Italy in the two tax periods before the move, a commitment to stay at least two years, and work done mainly in Italy (art. 16 comma 1). There was no five-year gap and no degree requirement for the main rule. Non-EU citizens with a degree could also qualify under art. 16 comma 2.
• It covered employment, similar and self-employment income, and from 2020 business income of people who start a business in Italy (art. 16 comma 1-bis).
• Workers who arrived before 30 April 2019, and professional athletes, have their own rules (the Redditi PF instructions list separate codes). Refer them.

Benefit

New regime, arrivals from 2024 (D.Lgs. 209/2023 art. 5, text in force on 30 June 2026)

What	Value	Note
Source	all figures below	https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:2023-12-27;209~art5!vig=2026-06-30
Share of qualifying income that counts towards taxable income	50%	"limitatamente al 50 per cento del loro ammontare"
Yearly limit of qualifying income the rule applies to	EUR 600,000	"entro il limite annuo di 600.000 euro"
Share that counts if the worker moves with a minor child, or a child is born or adopted during the regime	40%	"La percentuale di cui al comma 1 è ridotta al 40 per cento"
Share in the three extra years for 2024 movers who own their main home (comma 10)	50%	"limitatamente al 50 per cento del loro ammontare"

How the return describes it (Redditi PF 2026 instructions, for 2025 income)

What	Value	Note
Source	all figures below	https://www.agenziaentrate.gov.it/portale/documents/d/guest/pf1_istruzioni_2026
Reduction of employment income, new regime (code 16)	50 per cento	"nella misura del 50 per cento (codice 16)"
Reduction with a minor child, new regime (code 17)	60 per cento	"nella misura del 60 per cento (codice 17)"
Reduction, old regime (code 6)	70 per cento	"nella misura del 70 per cento (codice 6)"
Reduction, old regime, southern regions (code 8)	90 per cento	"nella misura del 90 per cento (codice 8)"

• What the share means. Only the share in the first table is added to taxable income. The rest is not taxed. So "50% taxable" and "a reduction of 50 per cento" describe the same rule; with a minor child, the taxable share falls to the 40% in the table and the return calls it a 60 per cento reduction.

• The yearly limit. The law says qualifying income "entro il limite annuo" counts at the reduced share. It does not spell out how income above the limit is treated; see "When to refuse or refer".

• The child condition. The minor child (or adopted minor) must be resident in Italy while the worker uses the regime (art. 5 comma 5). If the child is born or adopted during the regime, the lower share applies from that tax period for the time left (art. 5 comma 4(b)).

• Duration of impatriati benefit : the tax period of the move and the next four (art. 5 comma 3).

• Extension of benefit : the new regime has no general extension for children or a home. The only extension is for people who moved registered residence in 2024 and became owners of a home used as their main residence in Italy by 31 December 2023 and within the twelve months before the move: three extra tax periods at the share in the first table (art. 5 comma 10). Under the new regime a minor child lowers the taxable share; it does not extend the period.

Old regime, arrivals up to 31 December 2023 (D.Lgs. 147/2015 art. 16, text in force on 28 December 2023)

What	Value	Note
Source	all figures below	https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:2015-09-14;147~art16!vig=2023-12-28
Share of qualifying income that counts, first five years	30%	"limitatamente al 30 per cento del loro ammontare al ricorrere delle seguenti condizioni"
Share for moves to Abruzzo, Molise, Campania, Puglia, Basilicata, Calabria, Sardegna or Sicilia	10%	"La percentuale di cui al comma 1 è ridotta al 10 per cento per i soggetti che trasferiscono la residenza"
Share in the five extra years (at least one minor or dependent child, or a home bought in Italy)	50%	"negli ulteriori cinque periodi di imposta, concorrono alla formazione del reddito complessivo limitatamente al 50 per cento"
Share in the five extra years with at least three minor or dependent children	10%	"negli ulteriori cinque periodi di imposta, concorrono alla formazione del reddito complessivo limitatamente al 10 per cento"

• Old regime duration: the tax period of the move and the next four (art. 16 comma 3), plus five extra periods in the cases in the table (art. 16 comma 3-bis). The home may be bought by the worker, spouse, partner or children, after the move or in the twelve months before it.
• Someone who moved in 2023 is still inside the first five years in 2026 and uses the old shares, not the new ones.

What is excluded vs not

• Included in the benefit (new regime) : employment income, income treated as employment (redditi assimilati), and self-employment income from arts and professions, produced in Italy (art. 5 comma 1).
• Not included (new regime) : business income (reddito d'impresa) is not in the list in art. 5 comma 1, unlike the old regime. Investment income (dividends, interest, capital gains) and rental income are not in the list either; they are taxed under their normal rules. For those rules use the it-income-tax and italy-crypto-tax Guides.
• Old regime : employment, similar and self-employment income, plus business income for businesses started in Italy from 2020 (art. 16 comma 1 and 1-bis).

Regime 2: Flat Tax for new residents (Res Non-Dom: Art. 24-bis TUIR)

Who it's for

• Who the flat tax is for : individuals who move their residence to Italy under TUIR art. 2 comma 2 and were not Italian tax resident for at least nine of the ten tax periods before the option starts (art. 24-bis comma 1). There is no income or work test. Family members listed in Civil Code art. 433 who meet the same condition can be added (comma 6).

How it works

Amount for people who move from 1 January 2026 (L. 199/2025 art. 1 commi 25 and 26)

What	Value	Note
Source	all figures below	https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:legge:2025-12-30;199
Yearly substitute tax on foreign income	EUR 300,000	"sostituite dalle seguenti: «euro 300.000»"
Yearly amount for each family member added	EUR 50,000	"sostituite dalle seguenti: «euro 50.000»"

Amount for people who moved after D.L. 113/2024 came into force (art. 24-bis as in force from 10 August 2024 to 19 December 2025)

What	Value	Note
Source	all figures below	https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1986-12-22;917~art24bis!vig=2025-06-30
Yearly substitute tax on foreign income	EUR 200,000	"nella misura di ((euro 200.000)) per ciascun periodo"
Yearly amount for each family member added	EUR 25,000	"ridotto a euro 25.000 per ciascun periodo"

Amount in the original text (art. 24-bis as in force from 1 January 2017 to 9 August 2024)

What	Value	Note
Source	all figures below	https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1986-12-22;917~art24bis!vig=2024-01-01
Yearly substitute tax on foreign income	EUR 100,000	"nella misura di euro 100.000 per ciascun periodo"
Yearly amount for each family member added	EUR 25,000	"ridotto a euro 25.000 per ciascun periodo"

• Which amount applies. Each increase applies only to people who moved residence (Civil Code art. 43) after the change came into force: D.L. 113/2024 art. 2 comma 2 for the middle table, L. 199/2025 art. 1 comma 26 for the top table. Someone who moved in 2026 pays the amount in the top table. The notes do not say in words that earlier arrivals keep their old amount; that is the reading of the transitional rules, and the adviser should confirm it for the client's move date.
• Fixed amount. The tax is a fixed amount per year "a prescindere dall'importo dei redditi percepiti" (whatever the income). It is paid in one sum by the due date of the income tax balance, and it is not deductible from any other tax (comma 2).
• Italian-source income taxation : only foreign income is covered. Italian-source income stays in ordinary IRPEF at the rates in the table at the end of this Guide.
• A ruling first. The option is made after a favourable answer to a ruling request (interpello) to the Agenzia delle Entrate, by the return deadline for the year of the move, and it applies from that year (comma 3).

Duration

• Duration of the flat tax regime : the option can be revoked, and in any case ends fifteen years after its first tax period (comma 4). It is not "renewed" each year: it ends early if the tax is not paid in full and on time, and revocation or loss of the regime bars a new option (comma 4).

What it covers

Foreign income identified under TUIR art. 165 comma 2 (comma 1). Two limits apply:

• Capital gains on qualifying shareholdings (TUIR art. 67 comma 1 letter c) realised in the first five tax periods of the option are not covered and stay under the ordinary rules (comma 1).
• The taxpayer can exclude income from one or more countries; that income is then taxed normally with the foreign tax credit (comma 5). The notes to the article also report (L. 232/2016 art. 1 comma 153) that people under the option do not file the foreign-assets monitoring return of D.L. 167/1990 art. 4 and are exempt from the taxes of D.L. 201/2011 art. 19 commi 13 and 18.

Pensioners' option: flat rate on foreign income (TUIR art. 24-ter)

Substitute tax for foreign pensioners (TUIR art. 24-ter, text in force on 30 June 2026)

What	Value	Note
Source	all figures below	https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1986-12-22;917~art24ter!vig=2026-06-30
Yearly substitute tax on all foreign income	7%	"con aliquota del 7 per cento per ciascuno dei periodi"

• Who. People who receive pension income paid by foreign entities (TUIR art. 49 comma 2(a)) and move residence to a town in Sicilia, Calabria, Sardegna, Campania, Basilicata, Abruzzo, Molise or Puglia, or to certain earthquake-area towns, with a population of no more than 30,000 inhabitants (the text in force from 7 April 2026). They must not have been Italian tax resident in the five prior tax periods, and must move from a country with an administrative cooperation agreement (commi 1 and 2).
• What. Foreign income of any category, not only the pension (comma 1). Countries can be excluded, as under art. 24-bis (comma 8).
• How long and how. The option is made in the return for the year of the move and applies from that year; it is valid for the first nine tax periods after that (commi 4 and 5). The tax is paid in one sum by the income tax balance due date (comma 6).

Italy progressive income tax rates (for reference)

Italy progressive income tax rates (for reference): bracket limits (TUIR art. 11)

What	Value	Note
Source	all figures below	https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1986-12-22;917~art11!vig=
Top of the first bracket of taxable income	EUR 28,000	"a) fino a 28.000 euro, 23 per cento"
Top of the second bracket	EUR 50,000	"b) oltre 28.000 euro e fino a 50.000 euro, ((33 per cento))"

Rates for 2026 income (Agenzia delle Entrate)

What	Value	Note
Source	all figures below	https://www.agenziaentrate.gov.it/portale/imposta-sul-reddito-delle-persone-fisiche-irpef-/aliquote-e-calcolo-dell-irpef
First bracket	23%	"sull’intero importo"
Second bracket, from 2026 income	33%	"dal 35 al 33 per cento"
Old second-bracket rate, 2024 and 2025 only. Not for 2026	35%	"Dall’anno 2024"
Above the second bracket	43%	"sul reddito eccedente i 50.000 euro"

The Agenzia table still shows the 2024 and 2025 middle rate; the 2026 rate is in the note below that table. Regional and municipal surcharges are extra; see it-income-tax.

The method, step by step

1. Fix the move date and the kind of residence moved. The new impatriati regime turns on the move of tax residence from the 2024 tax year; the old regime on the move of registered residence (residenza anagrafica) by 31 December 2023 (D.Lgs. 209/2023 art. 5 commi 8 and 9, https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:2023-12-27;209~art5!vig=2026-06-30). The flat tax amount turns on the date residence moved under Civil Code art. 43 (TUIR art. 24-bis notes, https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1986-12-22;917~art24bis!vig=2026-06-30).
2. Test the impatriati conditions. Years abroad (three, six or seven), same employer or group, high qualification, most of the year worked in Italy, and the four-year stay (art. 5 commi 1 to 3, https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:2023-12-27;209~art5!vig=2026-06-30).
3. Employees: ask the employer to apply it in payroll. In ordinary cases the employer grants the benefit directly and shows the untaxed share in the Certificazione Unica. The "Casi particolari" box of the return is used only if the employer did not apply it and the requirements are met; the country of previous residence is then entered on the front page (Redditi PF instructions, https://www.agenziaentrate.gov.it/portale/documents/d/guest/pf1_istruzioni_2026).
4. Self-employed professionals: claim it in the Redditi PF return, entering the qualifying income at the reduced share, as the Redditi PF instructions describe (https://www.agenziaentrate.gov.it/portale/documents/d/guest/pf1_istruzioni_2026).
5. Flat tax: file the ruling request first, then opt in the return for the year of the move, and pay the yearly amount by the income tax balance due date (TUIR art. 24-bis commi 2 and 3, https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1986-12-22;917~art24bis!vig=2026-06-30).
6. Pensioners' option: opt in the return for the year of the move and pay by the balance due date (TUIR art. 24-ter commi 5 and 6, https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1986-12-22;917~art24ter!vig=2026-06-30).

Ask the client first

• On what date did you move your registered residence (anagrafe) to Italy, and from which tax year are you Italian tax resident?
• In how many of the last seven tax years were you Italian tax resident, and do you now work for the same employer or group you worked for abroad (or in Italy before you left)?
• What is your qualification, and does it meet D.Lgs. 108/2012 or D.Lgs. 206/2007?
• Did you move with a minor child who lives in Italy, or has a child been born or adopted since you moved?
• Is your income employment, professional (arts and professions) or business income, and roughly how much do you expect each year?
• For the flat tax or the pensioners' option: were you Italian resident in any of the last ten (or five) years, which foreign countries does your income come from, and in which town will you live?

When to refuse or refer

• Arrivals before 30 April 2019, professional athletes, and returning university lecturers and researchers: separate rules and codes apply. Refer to a commercialista.
• Someone who used an impatriati regime before and moved again: art. 5 has no express rule. Refer.
• Income above the yearly limit, or business income under the new regime: the text does not settle the treatment of the excess, and business income is not listed. Refer.
• Whether a qualification meets the high-qualification decrees, and whether work was done in Italy "for most of the tax period": questions of fact and of other laws. Refer.
• Leaving Italy within four years (clawback with interest), or de minimis state aid limits: refer.
• Flat tax: the ruling request itself, the choice of countries to exclude, qualifying shareholdings sold in the first five years, and the treatment of people who moved before 2026 at the older amounts. Refer.
• Treaty residence conflicts and exit taxes in the country of departure: outside this Guide.

Sources

• D.Lgs. 209/2023 art. 5 (in force on 30 June 2026): https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:2023-12-27;209~art5!vig=2026-06-30
• D.Lgs. 147/2015 art. 16 (in force on 28 December 2023): https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.legislativo:2015-09-14;147~art16!vig=2023-12-28
• TUIR art. 24-bis, three versions: https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1986-12-22;917~art24bis!vig=2026-06-30 , https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1986-12-22;917~art24bis!vig=2025-06-30 , https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1986-12-22;917~art24bis!vig=2024-01-01
• TUIR art. 24-ter: https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1986-12-22;917~art24ter!vig=2026-06-30
• L. 199/2025 (Budget Law 2026): https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:legge:2025-12-30;199
• TUIR art. 11: https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1986-12-22;917~art11!vig=
• Agenzia delle Entrate, IRPEF rates: https://www.agenziaentrate.gov.it/portale/imposta-sul-reddito-delle-persone-fisiche-irpef-/aliquote-e-calcolo-dell-irpef
• Agenzia delle Entrate, Redditi PF 2026 instructions, fascicolo 1: https://www.agenziaentrate.gov.it/portale/documents/d/guest/pf1_istruzioni_2026

Working paper only. The 2024 reform significantly changed the impatriati eligibility. Individuals who began the regime before 2024 should confirm their grandfathered status. Have a qualified Italian commercialista review before relying on either regime.

Contributed by OpenAccountants.