Wealth and investments across countries
Investment planning for people with ties to several countries. I am registered with OCF, no. 633610; tax, legal and immigration matters require qualified professionals and separate engagements.
Why Italy?
A move needs to be assessed alongside income, family, actual residence and obligations in each country involved.
The two main tax regimes for individuals relocating to Italy
Two different regimes: foreign income for new residents, eligible work income for inbound workers. Eligibility requires individual assessment.
New Residents Regime (Art. 24-bis TUIR)
Flat substitute tax on foreign-source income. Designed for high-net-worth individuals with significant international income flows.
- €300,000 per year; €50,000 for each qualifying family member included
- Maximum 15 tax periods; non-resident in Italy in at least 9 of the previous 10 periods
- The election is made in the tax return; an advance ruling is optional and does not replace it
- Italian-source income is excluded; qualifying shareholding gains are excluded for the first 5 periods
- Compare ordinary taxation, tax treaties and obligations remaining abroad
The new amounts under Law 199/2025, article 1(25–26), apply to people moving their residence to Italy under Civil Code article 43 from 1 January 2026. Transitional rules require checking actual dates; these do not automatically coincide with the tax-residence year.
Inbound Workers Regime (Legislative Decree 209/2023, Art. 5)
Relief on the taxable share of specified work income earned in Italy, not an income-tax rate reduced to 50%.
- Eligible income up to €600,000 a year: 50% taxable, or 40% in specified cases involving minor children resident in Italy
- Year of transfer plus 4 subsequent periods; commitment to remain tax-resident for at least 4 years
- Non-resident for the previous 3 periods; 6 or 7 for work with the same employer or group, depending on employment history
- Work performed mainly in Italy and high qualification or specialisation requirements
- Not all self-employment or business income qualifies; check income classification and article 5 conditions
The new regime derives from article 5 of Legislative Decree 209/2023 and applies from tax year 2024, with transitional rules. The special extension for certain 2024 registered-residence transfers is not an ordinary benefit for arrivals in 2026.
Services for International Clients
Flat Tax Planning
Assessing investment implications; eligibility and tax returns are reviewed with a tax professional.
Asset Protection
Review of concentration, liquidity and market risks. No structure guarantees immunity from losses or creditor claims.
Relocation Support
Preparing the financial picture before a move; residence and immigration procedures are handled by qualified specialists.
Trust & Fiduciary Structures
Assessing the role of investments in the plan. Establishment, legal advice and trust administration require separately appointed professionals and trustees.
Pension Planning
Inventory of pension rights across countries and expected income. Transferability and taxation depend on each system’s rules.
Confidential data handling
Documents are shared for service needs and legal obligations; methods and recipients are described in the privacy notice.
Insights for International Clients
In-depth articles on topics of international relevance: Flat Tax, asset protection, relocation to Italy and fiduciary planning.
Legal references and official sources
Primary sources for the requirements summarised here; the full rules and individual circumstances still need review.
Assessing investment implications; eligibility and tax returns are reviewed with a tax professional. Assessing the role of investments in the plan. Establishment, legal advice and trust administration require separately appointed professionals and trustees.
- L. 199/2025, art. 1, commi 25–26The new amounts under Law 199/2025, article 1(25–26), apply to people moving their residence to Italy under Civil Code article 43 from 1 January 2026. Transitional rules require checking actual dates; these do not automatically coincide with the tax-residence year.
- D.Lgs. 209/2023, art. 5The new regime derives from article 5 of Legislative Decree 209/2023 and applies from tax year 2024, with transitional rules. The special extension for certain 2024 registered-residence transfers is not an ordinary benefit for arrivals in 2026.
- TUIR, art. 24-bisFlat substitute tax on foreign-source income. Designed for high-net-worth individuals with significant international income flows.
- Investor Visa for ItalyResidence, residence permits and citizenship are separate procedures; investment does not automatically grant an EU passport
Sources consulted on 27 September 2026
Sharing information
Documents are shared for service needs and legal obligations; methods and recipients are described in the privacy notice.