Italy Flat Tax Regime for New Residents (Art. 24-bis TUIR)

Italy's Article 24-bis flat tax regime allows newly resident high-income individuals to pay a fixed annual substitute tax on all foreign-source income, capping their tax liability regardless of how much they earn abroad.

Overview

Italy's Article 24-bis TUIR flat tax regime (Regime Fiscale Agevolativo per Nuovi Residenti) is a special tax election available to individuals who transfer their tax residence to Italy and have not been Italian tax residents for at least 9 of the 10 years preceding the move.

Under the regime, all foreign-source income is subject to a single flat substitute tax (currently €200,000 per year) instead of ordinary Italian progressive income tax rates. Italian-source income remains subject to standard Italian taxation.

This is not a visa category itself. It is a tax election made after establishing Italian tax residence. It pairs most naturally with the Italy Investor Visa or other long-term residence routes for high-net-worth individuals.

Who it's for

  • High-income individuals whose earnings come primarily from foreign sources
  • New Italian residents who have not been Italian tax residents for at least 9 of the previous 10 years
  • Investors, entrepreneurs, and professionals relocating to Italy who want a predictable, capped annual tax burden on non-Italian income
  • Families considering Italy as their EU base for long-term lifestyle and estate planning

Requirements

RequirementDetail
Italian tax residenceMust become a tax resident in Italy, typically 183+ days per calendar year
Prior non-residenceMust not have been Italian tax resident for at least 9 of the 10 preceding tax years
Annual flat tax€200,000 per year as a lump-sum substitute tax on all foreign-source income
Per family member€25,000 per year additional for each eligible family member opting into the regime
Maximum durationUp to 15 tax years under current rules

What the regime covers and excludes

Covered (subject to flat €200,000 tax):

  • Dividends and capital gains from foreign investments
  • Foreign employment income
  • Foreign rental income
  • Foreign pension income

Not covered (taxed at ordinary Italian rates):

  • Italian-source employment income
  • Income from Italian businesses
  • Italian-source capital gains and dividends
  • Italian rental income

Steps

  1. Establish Italian tax residence by spending 183+ days in Italy in a tax year and meeting Italian domicile criteria
  2. Confirm you meet the 9-of-10 non-residence test with prior tax filings and records
  3. Elect into the regime in your Italian tax return for the first year of residence, declaring the option under Article 24-bis
  4. Pay the annual flat substitute tax (€200,000 base) each year, plus any additional per-family-member amounts
  5. File annual Italian tax returns declaring Italian-source income at ordinary rates and foreign income under the flat tax election

Key notes

  • The regime is available for up to 15 tax years. Plan for your post-regime tax structure before the election expires.
  • Tax advice from an Italian qualified advisor is essential before making the election; incorrect filings can result in losing the regime status
  • The annual €200,000 flat tax is paid regardless of actual foreign income level. It becomes less attractive if foreign income is below a certain threshold.
  • Italy does not require a minimum physical presence under the regime itself, but remaining a tax resident does require spending meaningful time in Italy
  • Review the investor visa alongside this regime. The two are frequently used together by high-net-worth relocation planners.

This content is for informational purposes only.