IT Impatriati

Two regimes: which applies

Two regimes: which applies

Regime	Who it's for
Impatriati	Qualifying workers (employed/self-employed) moving to Italy
€100k/€200k flat tax	High-net-worth individuals moving to Italy (no work requirement)

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

Eligibility (reformed rules from 2024)

• Non-residency requirement before transfer — Must not have been Italian tax resident in the 3 years preceding transfer (previously 2 years for most categories) (D.Lgs 209/2023)
• Commitment to remain resident — Must commit to remain Italian tax resident for at least 4 years (D.Lgs 209/2023)
• Predominant work in Italy — Must work predominantly in Italy (> 183 days of working days in Italy) (D.Lgs 209/2023)
• University degree requirement — Must hold a university degree (new requirement from 2024) (D.Lgs 209/2023)
• No prior benefit — Must not have already benefited from the impatriati regime previously (D.Lgs 209/2023)

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

• 5-year non-residency gap was required for the old 70% exclusion version; the rules varied by category. Those grandfathered under old rules retain their benefit.

Benefit

• 50% exclusion of employment/self-employment income — 50% of employment or self-employment income earned in Italy is excluded from Italian taxable income.

Effective rate examples

Income	Effective rate
Up to ~€28,000 (23% bracket)	~11.5% effective on full income
Top rate (43% bracket, €50k+)	~21.5% effective on full income

• Duration of impatriati benefit — 5 years (the year of transfer + 4 following)
• Extension of benefit — Extension of 3 more years (8 total) if: Taxpayer purchases a residential property in Italy, OR Has one or more minor children

What is excluded vs not

• Included in 50% benefit — Included in the 50% benefit: employment income (PAYE), self-employment income
• Not included in 50% benefit — NOT included: investment income (dividends, capital gains), rental income (these are taxed at normal Italian rates or flat imputed rates)

Regime 2: €100,000 Flat Tax (Res Non-Dom — Art. 24-bis TUIR)

Who it's for

• Who the €100k flat tax is for — High-net-worth individuals who transfer tax residence to Italy and have not been Italian tax residents for 9 of the previous 10 years. (TUIR Art. 24-bis)

How it works

• €100,000 annual flat tax on foreign income — Pay a €100,000 annual flat tax on ALL foreign-source income and gains (regardless of amount) (TUIR Art. 24-bis)
• Italian-source income taxation — Italian-source income taxed at normal Italian progressive rates (TUIR Art. 24-bis)
• Flat tax for additional family member — €25,000 EUR (flat tax for each additional family member who also opts in) (TUIR Art. 24-bis)

Duration

• Duration of €100k flat tax regime — 15 years (renewable annually by paying the flat tax). Can exit at any time. (TUIR Art. 24-bis)

What it covers

Foreign dividends, interest, capital gains, rental income, employment income from abroad — all covered by the €100k payment. No per-income-item analysis needed for foreign income.

Italy progressive income tax rates (for reference)

Italy progressive income tax rates (for reference)

Taxable income	Rate
Up to €28,000	23%
€28,001 – €50,000	35%
Above €50,000	43%

Sources

• D.Lgs. 209/2023 (reformed impatriati regime, effective 2024)
• TUIR Art. 24-bis (€100k flat tax for HNW non-doms)
• Agenzia delle Entrate: agenziaentrate.gov.it

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.