Overview
Italy's Article 24-bis TUIR flat tax regime (Regime Fiscale Agevolativo per Nuovi Residenti) is a special tax election available to individuals who transfer their tax residence to Italy and have not been Italian tax residents for at least 9 of the 10 years preceding the move.
Under the regime, all foreign-source income is subject to a single flat substitute tax (currently €200,000 per year) instead of ordinary Italian progressive income tax rates. Italian-source income remains subject to standard Italian taxation.
This is not a visa category itself. It is a tax election made after establishing Italian tax residence. It pairs most naturally with the Italy Investor Visa or other long-term residence routes for high-net-worth individuals.
Who it's for
- High-income individuals whose earnings come primarily from foreign sources
- New Italian residents who have not been Italian tax residents for at least 9 of the previous 10 years
- Investors, entrepreneurs, and professionals relocating to Italy who want a predictable, capped annual tax burden on non-Italian income
- Families considering Italy as their EU base for long-term lifestyle and estate planning
Requirements
| Requirement | Detail |
|---|---|
| Italian tax residence | Must become a tax resident in Italy, typically 183+ days per calendar year |
| Prior non-residence | Must not have been Italian tax resident for at least 9 of the 10 preceding tax years |
| Annual flat tax | €200,000 per year as a lump-sum substitute tax on all foreign-source income |
| Per family member | €25,000 per year additional for each eligible family member opting into the regime |
| Maximum duration | Up to 15 tax years under current rules |
What the regime covers and excludes
Covered (subject to flat €200,000 tax):
- Dividends and capital gains from foreign investments
- Foreign employment income
- Foreign rental income
- Foreign pension income
Not covered (taxed at ordinary Italian rates):
- Italian-source employment income
- Income from Italian businesses
- Italian-source capital gains and dividends
- Italian rental income
Steps
- Establish Italian tax residence by spending 183+ days in Italy in a tax year and meeting Italian domicile criteria
- Confirm you meet the 9-of-10 non-residence test with prior tax filings and records
- Elect into the regime in your Italian tax return for the first year of residence, declaring the option under Article 24-bis
- Pay the annual flat substitute tax (€200,000 base) each year, plus any additional per-family-member amounts
- File annual Italian tax returns declaring Italian-source income at ordinary rates and foreign income under the flat tax election
Key notes
- The regime is available for up to 15 tax years. Plan for your post-regime tax structure before the election expires.
- Tax advice from an Italian qualified advisor is essential before making the election; incorrect filings can result in losing the regime status
- The annual €200,000 flat tax is paid regardless of actual foreign income level. It becomes less attractive if foreign income is below a certain threshold.
- Italy does not require a minimum physical presence under the regime itself, but remaining a tax resident does require spending meaningful time in Italy
- Review the investor visa alongside this regime. The two are frequently used together by high-net-worth relocation planners.
This content is for informational purposes only.