Italy's Flat Tax for New Residents: Is It Now €300,000?

01

What is the flat tax?

Article 24-bis of the income tax code (TUIR) lets a person who becomes resident in Italy opt to pay a fixed substitute tax on income produced abroad, whatever its amount (art. 24-bis(1) and (2)). Italian-source income stays taxed in the normal way. The regime was introduced in 2017 (Law 232/2016, art. 1(152)).

02

How much is it now?

The amount depends on when you moved your residence to Italy under article 43 of the Civil Code:

The rise to €200,000 came from D.L. 113/2024, art. 2. The 2026 Budget Law raised it to €300,000 and the family amount to €50,000, for people moving from its entry into force on 1 January 2026 (Law 199/2025, art. 1(25) and (26)). Each change applies only to new arrivals, so an existing option keeps its original amount.

The tax is paid in one sum by the date for paying the income tax balance. Late or partial payment ends the regime, though earlier years stay valid (art. 24-bis(2) and (4)).

03

What changed in 2026?

Two things. First, the higher amounts above apply to arrivals from 1 January 2026. Second, Italy has rewritten its income tax code. D.Lgs. 117/2026 repeals articles 1 to 191 of the TUIR, article 24-bis included, and restates the regime as article 246 of the new code, from 1 January 2027 (arts 376 and 377). Article 246 keeps €300,000 and €50,000 and the same conditions. In our view, nothing changes for an option holder on 1 January 2027 except the article number.

04

Who qualifies?

You must move your tax residence to Italy and must not have been Italian tax resident for at least nine of the ten tax years before the option starts (art. 24-bis(1)). Nationality does not matter. Any family member you add must meet the same test, and family here means the relatives listed in article 433 of the Civil Code, such as a spouse, children and parents (art. 24-bis(6)).

05

What income does it cover?

All income produced abroad, identified under the foreign tax credit rules, with two limits (art. 24-bis(1) and (5)):

• Capital gains on qualified shareholdings realized in the first five years of the option stay taxed under the ordinary rules.
• Countries you exclude. You may leave out income from one or more countries. That income is then taxed normally and you get the foreign tax credit.

Option holders and their added family members do not file the foreign assets section of the return and do not pay the Italian taxes on foreign property and foreign financial assets (Law 232/2016, art. 1(153)). The regime cannot be combined with the Italian tax breaks for returning researchers or for impatriate workers (art. 1(154)).

06

How do you opt in?

The statute ties the option to a favorable answer to a ruling request (interpello) filed with the Revenue Agency. You exercise it by the deadline for the tax return for the year you moved, and it takes effect from that year. You must name the country or countries of your last tax residence, and the Agency passes that information to their tax authorities (art. 24-bis(3)).

You can revoke the option at any time, and it ends after 15 years. Once revoked or lost, it cannot be chosen again (art. 24-bis(4)). Family members can be added at any point during the option, and removing one does not affect you (art. 24-bis(6)).

07

What should families from Asia and the Gulf check?

Residence first. The flat tax is a tax option, not a visa. Non-EU nationals still need a residence route, such as the investor visa or the elective residence visa.

Timing. The amount is fixed by the date you move your residence. In our view, a family planning a move should treat €300,000 as the figure and watch the 2027 Budget Law.

Reporting at home. Your previous country of residence will be told about your option (art. 24-bis(3)). In our view, take advice at home on exit and on any continuing tax ties before you move.

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