Italy’s flat tax for new residents (Article 24-bis of the TUIR) lets a person who moves their tax residence to Italy pay a fixed annual substitute tax on all foreign-source income, instead of ordinary progressive income tax. For anyone transferring civil residence to Italy after 31 December 2025, the amount is €300,000 a year, plus €50,000 for each family member included. It lasts up to 15 years and also removes Italian wealth tax on foreign assets and Italian inheritance and gift tax on foreign assets. Italian-source income is still taxed normally.
Last checked: October 2026
In short:
- The annual flat tax has risen twice: €100,000 for those who moved up to 10 August 2024, €200,000 for those who moved after that date until the end of 2025, and €300,000 (plus €50,000 per family member) for those transferring residence after 31 December 2025 under budget law 199/2025.
- You qualify if you were not Italian tax resident for at least 9 of the 10 tax years before the move; the regime lasts up to 15 years and you opt in through your Italian tax return.
- It covers foreign income, IVIE and IVAFE (wealth taxes on foreign property and financial assets) and inheritance and gift tax on foreign assets, but not gains on qualified shareholdings sold in the first five years.
How the regime works
The regime replaces Italian income tax on foreign-source income with one fixed annual payment. You do not declare the detail of that foreign income on the Italian return, and you do not pay more if it rises. According to PwC’s Italy summary, the lump sum replaces income tax on foreign investments (interest, dividends and capital gains), wealth tax on real estate and financial investments held outside Italy, and the financial monitoring obligations in the Italian tax return.
Income that arises in Italy is outside the regime. Italian salary, Italian rental income or Italian dividends are taxed under the ordinary rules. PwC lists the 2026 national IRPEF rates as 23% up to €28,000, 33% to €50,000 and 43% above €50,000.
You can also exclude specific countries from the regime. Watson Farley & Williams notes that income from an excluded country is taxed under the ordinary rules, with a foreign tax credit.
How much it costs: the amount by move date
| Residence transferred to Italy | Main taxpayer, per year | Each family member, per year | Legal basis |
|---|---|---|---|
| Up to 10 August 2024 | €100,000 | €25,000 | Art. 24-bis TUIR as originally enacted (2017) |
| After 10 August 2024 to 31 December 2025 | €200,000 | €25,000 | Decree-Law 113/2024, art. 2 |
| After 31 December 2025 | €300,000 | €50,000 | Law 199/2025 (2026 budget law), art. 1, paragraphs 25-26 |
The 2024 change came in Decree-Law 113 of 9 August 2024, which replaced “euro 100.000” with “euro 200.000” in Article 24-bis, for people who moved their residence after it entered into force on 10 August 2024. The 2026 budget law (Law 199 of 30 December 2025) then raised the main amount to €300,000 and the family amount from €25,000 to €50,000. DWF reads the new rule as applying to people who transfer civil residence to Italy after 31 December 2025.
The amount is fixed by the year you move, and existing users keep their amount. PwC states that people who opted in 2024 at €100,000 continue at that amount to the end of the regime.
A rough break-even
Using PwC’s 2026 IRPEF brackets alone, ordinary national income tax reaches €300,000 at roughly €715,000 of taxable income. It ignores regional and municipal surcharges and the different rules for investment income, so treat it only as a sense check.
Who is eligible
The conditions, as set out by Watson Farley & Williams and the Agenzia delle Entrate’s implementing decision:
- Become Italian tax resident under Article 2 TUIR. PwC summarises the test as being registered with the resident population, or having residence or domicile in Italy, for more than 183 days in the year.
- Not have been Italian tax resident for at least 9 of the 10 tax years before the move. This applies to Italians returning as well as foreigners.
- Opt in through the Italian tax return for the year you became resident or the following year.
- Stay resident. The regime ends if you move your tax residence abroad, and it ends if you fail to pay the substitute tax.
There is no minimum investment and no minimum income. It is a tax option, not a visa: non-EU nationals still need a residence permit. See Golden visa countries (2026): which are open, closed and the cost.
What is covered and what is not
| Item | Under the flat tax |
|---|---|
| Foreign employment, business, rental and investment income | Covered by the lump sum |
| Foreign capital gains | Covered, except qualified shareholdings (below) |
| Gains on qualified shareholdings sold in the first 5 tax years | Not covered: taxed under ordinary rules |
| IVIE (tax on foreign real estate) | Not due |
| IVAFE (tax on foreign financial assets) | Not due |
| RW foreign-asset reporting in the tax return | Not required for covered assets |
| Italian inheritance and gift tax on foreign assets | Not due; only Italian assets are taxed |
| Italian-source income | Taxed under ordinary rules |
| Income from countries you exclude | Taxed under ordinary rules with foreign tax credit |
The capital gains carve-out matters for founders. Watson Farley & Williams quotes the rule that the regime “does not apply to gains realized in the first five tax periods of validity of the option, through paid transfer of qualified shareholdings.” If you plan to sell a significant stake in your company, an exit in years one to five is taxed in Italy under the ordinary rules.
The inheritance point is significant. Watson Farley & Williams says that while the option applies, Italian inheritance and gift taxes apply only to assets in Italy.
You cannot combine the regime with the 7% pensioners’ regime, according to Watson Farley & Williams. Combining it with the impatriate workers’ regime is in flux: an Agenzia delle Entrate ruling in December 2025 allowed it, but Decree-Law 38/2026 bars the combination from tax year 2027. Advisers read a transitional window for people who moved in 2024 to 2026, so confirm your position before relying on both.
Family members
You can extend the regime to family members as defined in Article 433 of the Italian Civil Code, which, alongside the spouse, covers relatives the law treats as entitled to maintenance. Each one must meet the same 9-of-10-years test and become Italian tax resident. The extension is made in each family member’s own tax return, and each pays the family amount: €25,000 for moves before 2026, and €50,000 for moves after 31 December 2025. A family member can revoke the option separately.
The ruling (interpello) process
An advance ruling is optional, but most advisers recommend one. The Agenzia delle Entrate’s implementing decision of 8 March 2017 sets out the process:
- What you file: personal details, confirmation that you were not resident in Italy for at least 9 of the 10 previous tax periods, the countries where you were previously resident, and any countries you want to exclude.
- Where: the Agenzia’s central assessment department, by certified email (PEC) to the address given in the decision, or by hand delivery.
- Timing: the response follows the standard interpello rules under Legislative Decree 156/2015. You can opt in through your tax return while the ruling is pending.
The ruling gives certainty on eligibility. It does not replace the election in the tax return.
How it compares with the impatriate regime
Italy’s other big incentive targets people who work in Italy. Since 2024 it is governed by Article 5 of Legislative Decree 209/2023.
| Flat tax for new residents (Art. 24-bis) | Impatriate regime (Art. 5, D.Lgs. 209/2023) | |
|---|---|---|
| What it taxes | Foreign-source income only | Italian employment and self-employment income |
| Benefit | Fixed €300,000 a year (moves from 2026) | Only 50% of qualifying income is taxable (40% with a minor child) |
| Income cap | None | €600,000 a year of qualifying income |
| Prior non-residence | 9 of the last 10 years | 3 years (longer if returning to the same employer or group) |
| Duration | Up to 15 years | 5 tax years |
| Commitment | None beyond staying resident | Stay resident at least 4 years |
| Other conditions | None on work | High qualification or specialisation; work mainly in Italy |
| Wealth and inheritance tax relief on foreign assets | Yes | No |
The impatriate regime suits a professional or founder who will earn income in Italy. The flat tax suits someone whose wealth and income sit outside Italy. From tax year 2027 you cannot use both at once (see above).
Who it suits, and who it does not
It can suit:
- Wealthy individuals with large foreign investment income, for example dividends, interest and gains from a portfolio or holding company outside Italy.
- Families with substantial foreign assets who want relief from IVIE, IVAFE and Italian inheritance and gift tax for up to 15 years.
- People planning an exit, provided the sale of a qualified shareholding falls after year five.
It is less likely to suit:
- Founders and remote workers on salary or business income below roughly €700,000. Italy’s other options, or a different country, will usually cost less. See Low-tax residency for high earners (2026): 14 regimes compared for the alternatives.
- Anyone planning to sell a significant shareholding soon after moving.
- People who will earn mostly Italian-source income, which the regime does not cover.
Remember that leaving your current country can trigger an exit tax, and your old country may still claim you as resident. Read Exit tax explained: which countries charge it when you leave and Tax residency explained: why the 183-day rule is a myth for most countries before you move.
Related guides: Low-tax residency for high earners (2026): 14 regimes compared · Greece non-dom regime (2026): €100,000 flat tax, investment and how to apply · Switzerland lump-sum taxation (2026): forfait fiscal, minimums and cantons · Exit tax explained: which countries charge it when you leave · Tax residency explained: why the 183-day rule is a myth for most countries
Quick answers
Q: How much is the Italian flat tax for new residents in 2026?
For people who transfer their civil residence to Italy after 31 December 2025, the flat tax is €300,000 a year on all foreign-source income, plus €50,000 a year for each family member included. People who moved after 10 August 2024 and by the end of 2025 pay €200,000, and earlier movers pay €100,000.
Q: How long does the Italian flat tax regime last?
Up to 15 tax years from the first year the option applies. It ends earlier if you revoke it in a later tax return, fail to pay the substitute tax, or move your tax residence out of Italy. You must not have been Italian tax resident for at least 9 of the 10 years before you move.
Q: Does the Italian flat tax cover capital gains?
Mostly yes. Foreign capital gains are covered by the lump sum, except gains on qualified shareholdings sold during the first five tax years of the option, which are taxed under the ordinary rules. Italian-source gains are always taxed normally. Founders planning an exit should time the sale after year five.
Sources
- Agenzia delle Entrate: Decree-Law 9 August 2024 no. 113, article 2 (PDF)
- Agenzia delle Entrate: implementing decision of 8 March 2017 on the new residents’ option (PDF, via Diritto Bancario)
- PwC Worldwide Tax Summaries: Italy, taxes on personal income
- PwC Worldwide Tax Summaries: Italy, residence
- DWF: 2026 budget law, key tax changes
- Diritto.it: the new residents’ regime after the 2026 budget law
- Watson Farley & Williams: the Italian non-domiciled tax regime
- Euroconference News: how the impatriate regime changes in 2024
- Hogan Lovells: Italy’s fiscal decree restores the non-cumulation rule for inbound workers and HNWIs
- eDotto: new residents and impatriates, no combining from 2027 (in Italian)
- eDotto: new impatriate regime 2024
This is general information from the Nomad Forums team, not legal, tax or financial advice. Rules change; check the official source or a qualified adviser before acting.
Over to you: Have you moved to Italy under the flat tax, and did you get an interpello ruling first? If you are weighing €300,000 against the alternatives, what income level made it worth it for you?