Italy Flat Tax Regime for High-Net-Worth New Residents
Italy ITA
Italy's flat tax regime for new residents (Art. 24-bis of the tax code) lets individuals who move tax residency to Italy pay one flat substitute tax on all foreign-source income and gains, instead of ordinary progressive taxation and Italy's foreign-asset wealth taxes. Aimed squarely at high-net-worth individuals, it requires the applicant not to have been an Italian tax resident for 9 of the prior 10 years. An August 2024 budget decree doubled the annual charge from €100,000 to €200,000 for new elections, though earlier participants were grandfathered at the lower rate. The regime runs up to 15 years, can extend to family members for €25,000 each, and is typically paired with an underlying immigration route — Elective Residency, an Investor Visa, or EU free movement — since the election itself confers no right to reside.
Program Details
- Category
- Other
- Processing Time
- 3 months
- Application Fee
- $300
- Minimum Income
- —
- Minimum Investment
- —
- Family Included
- €25,000/year (approximately $27,000) per additional qualifying family member (spouse, children, or other dependent relatives) included in the same substitute-tax election.
- Path to PR
- Yes — 5 years
- Path to Citizenship
- Yes — 10 years
- Physical Presence
- Applicant must become an Italian tax resident, generally meaning registration in the civil registry (Anagrafe) and/or presence in Italy for more than 183 days in the tax year, or establishing habitual abode/domicile in Italy. Must not have been an Italian tax resident for at least 9 of the preceding 10 tax years to qualify initially.
- Dual Citizenship
- Allowed
- Tax Impact
- The single flat substitute tax replaces ordinary Italian progressive income tax (up to 43%) on all foreign-source income and gains. It also exempts the beneficiary from Italy's foreign-asset wealth taxes (IVIE/IVAFE), from disclosing foreign assets on the RW tax-return schedule, and from Italian inheritance/gift tax on foreign assets. Italian-source income remains taxed under ordinary rules; the regime applies for a maximum of 15 tax years.
- Renewal Cost
- $216,000
There is no minimum foreign-income or net-worth threshold to elect into the regime. Instead, applicants pay a flat annual substitute tax on all non-Italian-source income regardless of amount: €200,000/year for elections made on or after 10 August 2024, or €100,000/year for those who validly opted in before that date and continue renewing year to year.
Application Timeline
Apply
3mo processing
Visa Granted
Initial permit
Permanent Residency
After 5 years
Citizenship
After 10 years
Key Requirements
- ✓Must not have been resident in Italy for tax purposes for at least 9 of the 10 tax years preceding the election
- ✓Must establish Italian tax residency (civil registry registration and/or 183+ days presence, or habitual abode/domicile in Italy)
- ✓A valid underlying immigration status or right to reside in Italy (Elective Residency visa, Investor Visa, EU citizenship, etc.), as the tax regime itself is not a residence permit
- ✓Timely election of the regime in the first Italian tax return following the change of residence, or via an optional advance ruling (interpello) request to the Agenzia delle Entrate
- ✓Annual payment of the flat substitute tax (€200,000, or €100,000 for pre-August-2024 elections) via the F24 tax form, regardless of actual foreign income earned that year
- ✓Optional supplemental €25,000 per family member if extending the election to include relatives
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Application Process — Step by Step
- 01
Secure an underlying Italian immigration status
home countryBecause the flat tax regime is a tax election, not a residence permit, applicants first obtain an underlying route to live in Italy, most commonly the Elective Residency visa (for those with independent passive income) or the Investor Visa for Italy (for those investing in Italian government bonds, companies, or philanthropy).
Typical duration: 2-4 months
- 02
Optional: request an advance ruling (interpello)
home countryApplicants with complex foreign holdings may request a non-binding advance ruling from the Agenzia delle Entrate confirming eligibility and treatment of specific foreign assets before formally electing the regime.
Typical duration: 4-5 months
- 03
Relocate and register Italian tax residency
destinationMove to Italy, register with the local Anagrafe (civil registry), obtain an Italian tax code (codice fiscale), and establish the intended physical presence or domicile that supports Italian tax residency for the year.
Typical duration: 2-6 weeks
- 04
Elect the regime in the first tax return
destinationFormally opt into the Art. 24-bis regime in the tax return covering the first year of Italian tax residency, specifying whether family members are being included in the same election.
Typical duration: Filed by the standard annual return deadline
- 05
Pay the annual flat substitute tax
destinationPay the flat substitute tax (€200,000, plus €25,000 per included family member) via the F24 form by the relevant June deadline each year the election remains in force, in lieu of ordinary tax on foreign income.
Typical duration: Annual, ongoing
- 06
Maintain the underlying residence status and renew annually
destinationContinue meeting the requirements of the underlying visa/residence route while renewing the flat tax election each year, for up to a maximum of 15 tax years.
Typical duration: Ongoing, up to 15 years
Gotchas — Things to Watch For
- ⚠The flat tax is due in full for the year regardless of how much foreign income was actually earned — it is not a cap on tax owed, but a fixed annual charge
- ⚠The regime confers no residence rights on its own; losing or failing to maintain the underlying visa (Elective Residency, Investor Visa, etc.) ends the ability to remain in Italy irrespective of the tax election
- ⚠The August 2024 doubling to €200,000 applies to anyone electing from that date forward, including people who move to Italy years later — only those who validly elected before the change keep the €100,000 rate
- ⚠Italian-source income and capital gains are explicitly excluded from the flat tax and remain subject to ordinary progressive Italian taxation, which can catch newcomers off guard
- ⚠The 9-out-of-10-year prior non-residence test is strictly enforced; recent Italian tax residency, even briefly, can disqualify an applicant
Frequently Asked Questions
Is the flat tax regime itself a visa or residence permit?+
No. It is a tax election available to individuals who already have, or separately obtain, a valid basis to reside in Italy — such as the Elective Residency visa, an Investor Visa, or EU freedom of movement. The tax regime and the immigration status are handled through entirely separate applications.
Why did the cost double in 2024?+
A budget decree effective 10 August 2024 raised the flat substitute tax from €100,000 to €200,000 per year for new elections, in response to concerns about the regime's popularity among ultra-wealthy relocators driving up housing costs in cities like Milan. Individuals who elected before that date generally keep the original €100,000 rate for the life of their election.
Does the flat tax cover all my worldwide income?+
It covers foreign-source income and capital gains only. Income and gains sourced in Italy remain taxed under Italy's ordinary progressive rates (up to roughly 43%), plus regional and municipal surtaxes.
Can I include my spouse and children in the same election?+
Yes. Qualifying family members can be added to the same flat-tax election for an additional €25,000 per person per year, rather than each needing to independently qualify and pay the full €200,000.
How long does the regime last?+
Up to a maximum of 15 tax years from the year the Italian tax residency and election first take effect. After that period (or upon voluntary revocation, or failure to pay the annual charge), the individual reverts to ordinary Italian worldwide taxation.
Applying from a specific country? Your home-country tax rules, banking access, and dual-citizenship options affect every programme differently. Browse nationality guides → for tax obligations, renunciation rules, and second-passport routes.
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