Special tax regime for new residents
Italy’s Budget Law for 2017 has introduced several measures aimed at bolstering the attractiveness of the country for human and financial capital from abroad. One of them is particularly relevant for anyone interested in an Investor Visa for Italy: a special tax regime targeted at new residents holding substantial sources of income abroad.
Article 24-bis of Italy’s Tax Code (TUIR) provides for an optional tax regime that allows new residents to substitute regular taxation on their entire income generated outside Italian territory by paying, once a year, a €100,000 lump sum.
The new regime is applicable, upon request, to anybody who is willing to move their tax residence to Italy, under the condition that he or she has not been resident in the country for at least 9 out of the last 10 years. The person concerned may request a probatory ruling by the Italian Revenue Agency.
The €100,000 substitutive tax is to be paid in one instalment by 30 June of each year. Family members may also be covered by the scheme by paying an additional €25,000 for each dependent.
Once granted, the regime is valid for 15 years and the taxpayer can opt out at any time. The status automatically lapses in the event of failure to pay the annual lump sum, partly or in full.
The special regime also applies to inheritance tax – which only covers assets located in Italy – and to transfers of foreign assets from abroad, which are untaxed. Applicants can also decide to opt out of the special regime on income and gains realised in selected foreign countries, in which case ordinary legislation will apply.
The status is compatible with employment and other professional activities carried out in Italy and taxable according to ordinary provisions in force.
Want to know more?
Instructions on how to apply for a preliminary probatory ruling (info in English – Italian) can be found on the same website, along with the check list to be attached to the application (Guidelines, in Italian)