Tax Residence of Individuals in Italy

The Legislative Decree No. 209/2023 amended the notion of tax residence set forth by Art. 2(2) of the Italian Tax Code. The new rules have been further commented on by the Circular n. 20/E/2024 issued by the Italian Tax Authorities. For individuals, the new provisions are as follows:

Pre-existing rule (in force until 31st December 2023)Current rule (applicable from 1st January 2024)
IndividualsFor income tax purposes, individuals are considered residents if, for the greater part of the tax year,
  • They are registered in the registry of the resident population; or
  • They have their domicile or residence in the territory of the State, according to the Civil Code.
A person is considered a resident of Italy if, for the greater part of the tax year (more than 183 days or 184 in a leap year), also considering fractions of the day, if he/she:
  • is registered as a resident in the Register of Resident Population (“Anagrafe”) kept by Municipality (rebuttable presumption); or
  • has a fiscal domicile in Italy; or
  • has a residence as defined by the Civil Code in Italy; or
  • is physically present in Italian territory.

CM Group offers a comprehensive suite of services, combining high level advisory, seamless implementation, and strategic engagement of external professionals, to expertly assist clients in successfully relocating to Italy and establishing their tax residence.

Residency options:

“FLAT TAX” REGIME:

The Flat Tax Regime introduced in 2017 allows new Italian tax residents to pay a fixed annual tax of 200.000€ on foreign-sourced income, regardless of its amount.

A special anti-abuse provision exists regarding certain types of shareholding. It is valid up to 15 years and can include family members for an additional 25.000€ per person. Italian-sourced income is subject to ordinary taxation rules.

KEY PROSIDEAL FOR
  • Simplicity in global taxation
  • Certainty of Tax Liability
  • Inheritance and Gift Tax Exemption
  • Global mobility benefits
  • Family Inclusion
  • Long-term Stability
  • Wealthy individuals with significant foreign income or investments.
  • Entrepreneurs, investors, or retirees with global assets who want to minimize tax complexity and liability.
  • Families relocating to Italy seeking a fixed and capped tax solution.

CM Group provides tailored support to individuals interested in benefiting from Italy’s Flat Tax regime.  Our holistic approach ensures that clients receive seamless assistance navigating the application process, structuring their assets, and fully leveraging this unique fiscal opportunity.

ITALIAN IMPATRIATE REGIME:

The Impatriate Regime offers significant tax incentives to individuals relocating to Italy for work. The regime lasts 5 years and can be extended for an additional 5 years under certain conditions. The income derived from employment or self- employment arrangements benefits from 50 % to 60% tax exemptions (limited to 600.000€). Foreign income is subject to Italian taxation.

KEY PROSIDEAL FOR
  • Substantial Tax reduction (more exemptions for individuals relocating to southern Italy)
  • Wide eligibility
  • Extended duration
  • Support for families
  • Employees or freelancers planning to move to Italy.
  • High-income earners seeking to reduce their tax burden.
  • Southern Italy to benefit from Tax Advantages.

CM Group delivers bespoke solutions for individuals looking to take advantage of Italy’s Impatriate Regime. We guide clients through every step of the process, ensuring they maximize the benefits of the regime while seamlessly transitioning their professional and personal life to Italy.

VISA OPTIONS

ELECTIVE VISAINVESTOR VISA

Only for residential purposes. Requires proof of stable income outside the country.

The elective VISA does not allow someone to carry out any work activity while in Italy.

Designed for HNWI willing to make substantial investments in Italy.

Contact Us

Cone Marshall Trustees (Italia) Srl

Via della Spiga, 52

20121 – Milan, Italy

+39 02 800 123 79

italy@conemarshall.com