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Italy's New Residents Flat Tax 2026: What Changed from €200,000 to €300,000

Alessandro Vigni
Alessandro VigniFinancial AdvisorOCF #633610
Published on 5 min read
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Italy's 2026 Budget Law introduced the first substantial amendment to the new residents optional regime since the August 2024 Omnibus Decree. The flat substitute tax on foreign-sourced income under Article 24-bis TUIR rises from €200,000 to €300,000/year for individuals transferring residence under Article 43 of the Italian Civil Code from 1 January 2026. For family members the amount rises from €25,000 to €50,000/year each.

📌 At a glance (official 2026 data)

  • • Main applicant: from €200,000 to €300,000/year (+50%)
  • • Family members (each): from €25,000 to €50,000/year (+100%)
  • • Effective date: tax residence transfers from 1 January 2026
  • • Legal basis: Law 30 December 2025, no. 199, Art. 1 paragraphs 25-26 (2026 Budget Law)
  • • Non-retroactive: prior electors keep their original amount

Cost evolution of the regime

The new residents optional regime (Art. 24-bis TUIR) was introduced by Law 232/2016 with an initial flat tax of €100,000/year. The history of amendments:

Residence transfer period Main applicant Family member Legal basis
2017 — 9 Aug 2024€100,000€25,000L. 232/2016 art. 1 c. 152
10 Aug 2024 — 31 Dec 2025€200,000€25,000D.L. 113/2024 art. 2 (Omnibus)
From 1 Jan 2026€300,000€50,000L. 199/2025 art. 1 cc. 25-26

The progression €100,000 → €200,000 → €300,000 applies to different residence-transfer cohorts, not successive increases for the same person. The maximum is 15 tax periods, with prior non-residence in Italy for at least nine of ten periods. Only eligible foreign-source income is covered: the qualifying shareholding gains specified by law are excluded in the first five periods, and selected countries can be excluded from the election. The election is made in the tax return; an optional advance ruling does not replace it. Payment is made in one instalment through Form F24, code NRPP.

Pre-2026 transfers: grandfathering

Article 1, paragraph 26 of Law 199/2025 explicitly states the new amounts apply only to persons transferring residence under Article 43 of the Italian Civil Code from the effective date of the law.

Earlier cohorts retain the amounts set by their transitional rules, subject to a genuine transfer, eligibility, a valid election and continued application of the regime. The tax-return filing date alone does not select a lower amount. In addition to the original €100,000 cohort, the following list compares the two more recent cohorts:

  • Transfers between 10 August 2024 and 31 December 2025: pay €200,000 + €25,000 until 15-year term ends
  • Transfers from 1 January 2026: pay €300,000 + €50,000 until 15-year term ends

The comparison depends on the income actually covered and ordinary tax otherwise due, not a fixed wealth threshold. For illustration, if the same €1,000,000 were fully taxable at 26%, ordinary tax would be €260,000, below €300,000. Equality occurs at about €1,153,846 before foreign withholding, credits, exclusions and other rules. Over 15 years, €300,000 rather than €200,000 costs €1.5 million more; compared with €100,000, €3 million more. This arithmetic is not a personalised eligibility or benefit assessment.

New break-even point

The comparison depends on the income actually covered and ordinary tax otherwise due, not a fixed wealth threshold. For illustration, if the same €1,000,000 were fully taxable at 26%, ordinary tax would be €260,000, below €300,000. Equality occurs at about €1,153,846 before foreign withholding, credits, exclusions and other rules. Over 15 years, €300,000 rather than €200,000 costs €1.5 million more; compared with €100,000, €3 million more. This arithmetic is not a personalised eligibility or benefit assessment.

Official sources

Professional disclaimer: this article is for general information only. The financial advisory services provided cover wealth planning and investment allocation. Detailed tax analysis, exercise of the election via return/advance ruling, and tax filings require a licensed Italian commercialista. Alessandro Vigni coordinates partner professionals for tax matters.

Scope and transition: €300,000 for the main taxpayer and €50,000 for each included family member apply to transfers of residence under Article 43 of the Civil Code from 1 January 2026 (Law 199/2025, paragraphs 25–26). Access still requires the tax-residence and prior non-residence conditions. Italian-source income is outside the option; gains from qualified participations are excluded in the first five tax periods, subject to the applicable provisions. Country exclusions, foreign taxes, treaties, reporting and inheritance/gift rules need separate review.

Sources and scope

Background documents retain their stated period. Examples and analysis are illustrative, not forecasts or personal recommendations.

Questions and answers

How much is Italy's flat tax for new residents from 1 January 2026?

From 1 January 2026 the flat substitute tax is €300,000/year (was €200,000 until 31/12/2025). Family members €50,000/year each (was €25,000). New figures apply only to residence transfers from 1 January 2026 — Law 30 Dec 2025, no. 199, Art. 1, paragraphs 25-26.

Do those who already elected the option now pay €300,000?

No. Those who elected in prior years keep the amount in force at their transfer: €100,000 for transfers up to 9 August 2024, €200,000 for transfers between 10 August 2024 and 31 December 2025. The amendment is not retroactive.

Educational content, not a personal investment recommendation or financial, tax or legal advice. Simulations depend on the stated assumptions and invested capital can be lost. Author: Alessandro Vigni, financial adviser authorised in Italy to offer financial services away from business premises, OCF register no. 633610.