Italy flat tax for new residents: €300,000, 7% and impatriates

What this covers

Italy has three separate regimes for people who move there. Article 24-bis lets a new resident replace ordinary personal income tax (IRPEF) on foreign income with a fixed yearly amount, whatever that income is. Article 24-ter lets people with foreign pensions who move to small municipalities in southern Italy pay a 7% substitute tax on all foreign income. The impatriate regime in article 5 of Legislative Decree 209/2023 taxes only part of the Italian employment and self-employment income of qualified workers who move to Italy from 2024.

Start with Italian tax residence

All three regimes assume that the person becomes tax resident in Italy. From 2024, after Legislative Decree 209/2023, a person is resident if for most of the tax period they have their civil-law residence or domicile in Italy, are physically present there counting fractions of a day, or are enrolled in the resident population registry, which is now a rebuttable presumption. See the Italy country record and the tax residence entry.

Most of the tax period means 183 days, or 184 in a leap year. Circular 21/E of 2020 gives an example: a person who moves after 2 July cannot be resident for that year and can start a regime only the following year.

Check the article 24-bis substitute tax on foreign income

The Agenzia delle Entrate says article 24-bis is open to people who transfer their tax residence to Italy and were not resident there for at least nine of the ten tax periods before the option takes effect. Nationality does not matter.

The yearly amount has changed twice. The Agenzia's page says it was €100,000 until 10 August 2024, then €200,000 after Decree-Law 113/2024, with €25,000 for each family member. A notice on the same page, updated 16 January 2026, says the 2026 budget law raised it to €300,000, and to €50,000 for each family member, for people who move their residence to Italy from 1 January 2026. The Agenzia lists the 2026 change as article 1, paragraphs 25 and 26, of Law 199/2025. Check which amount applies to the year you moved.

The amount is fixed whatever the foreign income is. The option renews automatically each year and its effects end fifteen years after the first tax period it applies. It ends early if it is revoked, if the tax is paid late or only in part, or if the person moves their residence to another country.

Know what article 24-bis covers and leaves out

Italian-source income stays taxed under the ordinary rules. Circular 17/E of 2017 says gains from the sale of qualified shareholdings realized in the first five tax periods of the option are left out of the substitute tax and follow the ordinary rules.

The person can name foreign states whose income they want to keep outside the regime. That income is then taxed in the ordinary way. Circular 17/E also says the option exempts the person from reporting foreign assets in the monitoring section of the return and from the Italian taxes on foreign property (IVIE) and foreign financial assets (IVAFE) for the jurisdictions covered. The Agenzia's English page says inheritance and gift tax for these people applies only to assets in Italy.

The option is made in the tax return for the year of the move or the following year. A ruling request (interpello) to the Agenzia is optional. The tax is paid in one installment by the deadline for the income tax balance, with tax code NRPP, and late payment through voluntary correction is not allowed.

Compare the 7% regime for foreign pensioners in southern Italy

Article 24-ter lets people who receive pension income from foreign payers and move their tax residence to Italy pay a 7% substitute tax on foreign income of any category. The Agenzia's page, updated 8 May 2026, says the municipality must be in Sicily, Calabria, Sardinia, Campania, Basilicata, Abruzzo, Molise or Puglia with no more than 30,000 inhabitants, or be a municipality of up to 30,000 inhabitants hit by the 2009 L'Aquila or 2016 central Italy earthquakes.

The population limit was 20,000 until a law of 11 March 2026 (article 26), published in the Official Gazette on 23 March 2026, replaced it with 30,000. The Agenzia says the 30,000 limit has applied since 7 April 2026. Population is measured on the ISTAT figure at 1 January of the year before the first year of the option.

Circular 21/E of 2020 says the person must not have been resident in Italy for at least five tax periods before the option takes effect, and must move from a country with which Italy has administrative cooperation agreements in tax matters. The option lasts up to ten tax periods, the first year plus nine more. The circular also describes the exemption from foreign asset monitoring and from IVIE and IVAFE, and the right to leave income from named states outside the 7% tax.

Look at the impatriate regime for workers

The impatriate regime is different. It covers income earned in Italy, not foreign income. The Agenzia says that under article 5 of Legislative Decree 209/2023, employment, similar and self-employment income produced in Italy by workers who move from 2024 counts toward taxable income for only 50% of its amount, up to €600,000 a year. The taxed share falls to 40% for workers who move with a minor child, or who have or adopt a child during the regime, if the child is resident in Italy.

The worker must not have been resident in Italy in the three prior tax periods. That rises to six periods if they work for the same employer or group they worked for before leaving, and seven if they were previously employed in Italy by that employer or group. They must commit to stay resident for at least four years, work in Italy for most of the tax period, and meet the high qualification or specialization requirements of Legislative Decrees 108/2012 and 206/2007.

The regime runs for the year of the move and the four following tax periods. If the person does not stay for four years, the benefit is lost and recovered with interest. Moves up to 2023 fall under the older regime in article 16 of Legislative Decree 147/2015, which the Agenzia describes on a separate page. See the impatriate regime entry.

Compare the three Italian regimes side by side

The regimes target different people and different income. The table sets out the main features from the Agenzia's pages and circulars. It does not show which one is cheaper for anyone, because that depends on the facts.

Common misconceptions

Questions to take to a professional

1. In which tax year will I become resident in Italy under the 2024 residence rules?
2. Was I resident in Italy in any of the tax periods the regime I am considering looks back at?
3. Which article 24-bis amount applies to the date I moved, and which family members would I include?
4. Which foreign states, if any, should I leave outside the substitute tax, and how would that income then be taxed?
5. Would any gains on qualified shareholdings fall in the first five tax periods of the option?
6. If I am a pensioner, does my chosen municipality meet the population test on the relevant ISTAT date?
7. If I am a worker, do I meet the qualification and four-year commitment for the impatriate regime?

Questions people ask

Sources

• Neo residenti - Regime opzionale - Che cos'è (Agenzia delle Entrate)Official guidance
• Cittadini - Neo residenti - Regime opzionale - Normativa e prassi (Agenzia delle Entrate)Official guidance
• Circolare n. 17/E del 23 maggio 2017: regimi agevolativi per persone fisiche che trasferiscono la residenza fiscale in ItaliaOfficial guidance
• Tax regime for new residents (Agenzia delle Entrate, English page)Official guidance
• Regime opzionale per i pensionati esteri - Che cos'è (Agenzia delle Entrate)Official guidance
• Circolare n. 21/E del 17 luglio 2020: imposta sostitutiva per i titolari di redditi da pensione di fonte estera (articolo 24-ter TUIR)Official guidance
• Gazzetta Ufficiale, 23 marzo 2026: legge 11 marzo 2026, articolo 26 (Misure in favore dei centri urbani di medie dimensioni e per l'attrazione degli investimenti)Primary law
• Lavoratori impatriati, nuovo regime (dal periodo d'imposta 2024) - Che cos'è (Agenzia delle Entrate)Official guidance
• Agevolazioni per chi trasferisce la residenza in Italia (Agenzia delle Entrate)Official guidance
• Circular No. 20/E of 4 November 2024 (courtesy translation)Official guidance