08/05/2026
Italy’s Tax Regime for New Residents: Com-plete Guide to Article 24-bis TUIR (2026 Up-date)
Introduction
Italy has established itself as one of Europe’s leading jurisdictions for internationally mobile high-net-worth individuals through the preferential tax regime set out in Article 24-bis of the Italian In-come Tax Code (TUIR).
Commonly referred to as the “Italian flat tax regime for new residents”, this framework allows qua-lifying individuals transferring their tax residence to Italy to substitute ordinary taxation on foreign-source income with a fixed annual lump-sum tax.
Following the 2026 Budget Law (Law No. 199 of 30 December 2025), the regime remains structu-rally intact but has undergone significant financial adjustments. This guide provides a comprehensi-ve overview of the current rules, costs, benefits and strategic planning considerations.
1. What Is Italy’s Flat Tax Regime for New Residents?
Article 24-bis TUIR allows individuals who transfer their tax residence to Italy to opt for a substitu-te tax on foreign-source income.
Key features:
• flat annual substitute tax;
• no link to the actual amount of foreign income;
• optional and revocable election;
• maximum duration of 15 years.
Italian-source income remains subject to ordinary Italian taxation.
The regime was designed to attract entrepreneurs, investors, executives and family offices seeking a stable EU jurisdiction combined with tax predictability.
2. Who Can Access the Regime?
Access is subject to specific eligibility criteria:
• the individual must transfer tax residence to Italy;
• the applicant must not have been tax resident in Italy for at least 9 out of the 10 tax years preceding the transfer;
• a formal election must be made in the Italian tax return.
The regime applies on an individual basis and may be extended to eligible family members upon re-quest.
3. How Much Does the Regime Cost in 2026?
As from 1 January 2026, the financial thresholds are as follows:
Main Applicant
• EUR 300,000 per year (increased from EUR 200,000)
Each Eligible Family Member
• EUR 50,000 per year (increased from EUR 25,000)
The substitute tax remains fixed, irrespective of the actual foreign-source income received.
Grandfathering Clause
Individuals who exercised the option before 1 January 2026 continue to apply the substitute tax in force at the time of entry (EUR 100,000 or EUR 200,000 depending on the relevant year).
Timing therefore represents a critical planning variable for prospective applicants.
4. Key Tax Benefits of Article 24-bis
Despite the increase in cost, the regime preserves significant structural advantages.
Exemption from Tax on Foreign-Source Income
Foreign-source income is covered by the substitute tax and does not trigger ordinary progressive Ita-lian income taxation.
No IVIE and IVAFE
New residents opting for the regime are exempt from:
• IVIE (Italian tax on foreign real estate);
• IVAFE (tax on foreign financial assets).
No Foreign Asset Reporting (RW Form)
Participants are not required to report foreign assets in the Italian tax return for monitoring purposes.
Inheritance and Gift Tax Exemption on Foreign Assets
Foreign-located assets are excluded from the scope of Italian inheritance and gift tax.
This feature is particularly relevant for long-term wealth preservation and succession planning.
5. Strategic Planning Considerations
The 2026 reform shifts the regime towards ultra-high-net-worth individuals, making a detailed pre-relocation analysis essential.
Key areas requiring coordinated assessment include:
• multi-jurisdictional tax modelling;
• interaction with controlled foreign corporation (CFC) rules;
• trust and holding company structures;
• exit tax implications in the country of origin;
• corporate relocation or investment structuring;
• family governance and succession planning.
The decision to relocate before or after 1 January 2026 may produce materially different long-term outcomes.
6. Comparison with Other European Regimes
When assessing relocation to Italy, clients often compare alternative frameworks, including:
• the former Portuguese Non-Habitual Resident (NHR) regime;
• the Swiss lump-sum taxation system;
• the evolving UK non-domiciled regime.
Italy’s regime remains competitive due to its predictability, fixed exposure and clear statutory fra-mework.
7. Why Italy Remains Attractive for International HNWIs
Beyond the fiscal dimension, Italy offers:
• access to the European Union single market;
• a sophisticated legal system;
• established wealth management infrastructure;
• favorable succession rules;
• high quality of life and strategic geographic positioning.
For many internationally mobile families, Italy represents a balanced combination of lifestyle, stabili-ty and tax certainty.
8. How We Assist International Clients Relocating to Italy
Relocating tax residence under Article 24-bis TUIR is not merely a fiscal election — it is a strategic cross-border decision affecting asset protection, governance and long-term wealth structuring.
As a full-service international law firm, we provide integrated assistance covering:
• international tax planning and pre-relocation modelling;
• coordination with foreign tax advisors and family offices;
• immigration and residence procedures;
• corporate and investment structuring;
• real estate acquisitions;
• succession and estate planning;
• ongoing compliance and reporting.
Each relocation project is managed through a multidisciplinary approach, ensuring legal certainty, risk mitigation and alignment with the client’s long-term objectives.
For a confidential assessment of your position, please contact our Private Clients and International Tax Team.
