Individuals meeting article 24-bis TUIR requirements, including non-residence for at least nine of the preceding ten tax periods. Eligibility is individual.

What is payable from 2026?

Under the new effective-date rules in Law 199/2025: €300,000 annually and €50,000 per eligible family member. Earlier moves follow the rules applicable to their transfer.

Is all income included?

No. Italian income remains ordinarily taxable and exclusions apply. Income source, substantial shareholdings and any excluded countries need review.

Does moving guarantee a tax benefit?

No. Compare actual taxes, relocation costs, restrictions and family circumstances. Financial advice does not replace the tax adviser’s engagement.

Flat Tax for new residents — Art. 24-bis…

The regulatory framework

Applicants must not have been Italian tax residents for at least nine of the preceding ten tax periods. The maximum duration is fifteen tax periods; the regime does not apply to every relocation.

Decree-Law 113/2024 raised the amount from €100,000 to €200,000 for transfers of residence under article 43 of the Civil Code after its entry into force.
Law 199/2025, article 1 paragraphs 25–26, raised the amounts to €300,000 and €50,000 per eligible family member. These apply to transfers of residence under article 43 of the Civil Code from 1 January 2026.

The year the option is exercised is not enough: the date and nature of the move determine the applicable rules. Italian-source income remains subject to ordinary rules.

Break-even: when it really pays off

A tax comparison starts with the composition and source of income, not total wealth.

Mathematical example at 26%

€300,000 / 26% ≈ €1,153,846 of income.

Illustrative assumption: all income considered is taxed at 26% and covered by the option. Foreign tax credits and other taxes are excluded.

Income subject to progressive tax

Simply dividing €300,000 by the highest 43% rate is not a valid comparison.

Tax bands, deductions, territorial source, treaties and credits can change the result. Both alternatives need an actual calculation.

The regime has exclusions, including certain gains on substantial shareholdings in the first five tax periods. Work performed in Italy does not become foreign income merely because the client is abroad. A tax adviser must verify this.

Three checks before relocating

A residence decision involves tax rules, work and family circumstances. Comparing countries requires current sources for each jurisdiction.

Residence: check civil, tax and treaty criteria.
Income: establish source, type, foreign taxes and exclusions.
Family: verify individual eligibility and applicable amounts before extending the option.

Operational aspects and timing

Gather evidence of previous residence and income.
Check the option and payment procedures with a tax adviser.
Consider whether a ruling request to the Revenue Agency would resolve specific uncertainties.
Keep tax and legal appointments distinct from investment decisions and banking relationships.

Verifiable primary sources

Are you evaluating relocation to Italy and want a break-even simulation for your specific profile?

New-resident flat tax analysis

Flat Tax for new residents — The €300K regime from 2026