The Regime for New Tax Residents is a tax incentive designed for individuals who transfer their tax residence to Italy and earn income produced abroad. It allows them to pay a fixed annual substitute tax instead of ordinary IRPEF on foreign‑source income.

Who can access the regime

Eligible individuals are those who:

• transfer their tax residence in Italy;
• have not been tax residents in Italy for at least 9 out of the 10 years preceding the option.

The option may also be extended to qualifying family members (same requirements).

Ruling (Interpello)

In principle, a “probative” tax ruling is required, but it has been optional since 2017.

How to apply the option

The option is formalized through:

• the annual income tax return (Form NR section), or
• a “remission in bonis” procedure if it was omitted (with a €250 penalty).

Which income is covered

All foreign‑source income is included, according to the criteria of Art. 165 TUIR, such as:

• foreign real estate income;
• foreign investment income;
• employment income earned abroad;
• self‑employment income based abroad;
• business income from a foreign permanent establishment;
• capital gains from foreign participations;
• cryptocurrency income not held with Italian intermediaries.

Income earned through interposed entities (e.g., holding companies, trusts) is also covered.

Excluded income:

• Capital gains from qualified participations realized within the first 5 years.

Excluding specific countries

The taxpayer may choose to exclude one or more countries from the regime.
For those countries:

• income is taxed under ordinary rules;
• the foreign tax credit is available.

The choice is irreversible.

Substitute tax

This is a fixed annual tax on foreign‑source income, regardless of the amount of income.

Current amounts:

• €300,000 per year for individuals transferring residence from 1 January 2026;
• €200,000 for transfers between 11 August 2024 and 31 December 2025;
• €100,000 for transfers up to 10 August 2024;
• For family members: €50,000 per year from 2026 (previously €25,000).

Payment is made in a single instalment.

Effects of the option

During this regime, the taxpayer:

• does not file the RW form (except for qualified participations in the first 5 years);
• does not pay IVIE or IVAFE.

Duration, withdrawal and termination

• Duration: 15 years, non‑renewable.
• Withdrawl is allowed at any time.
• Termination occurs if:
  • the substitute tax is not paid;
  • residence is transfered abroad.

Family members may continue the regime independently.

Successions and donations

If the taxpayer dies or makes a gift during the regime:

• inheritance/gift tax applies only to assets located in Italy;
• foreign assets are exempt.

If certain countries were excluded from the regime, the exemption does not apply for assets located in those countries.

Summary

The Regime for New Tax Residents:

• is designed to attract high‑net‑worth individuals relocating to Italy;
• replaces ordinary IRPEF on foreign income with a single fixed tax;
• eliminates several compliance obligations (RW, IVIE/IVAFE, CFC);
• lasts 15 years with no possibility of renewal.

In December 2025, amendments were issued concerning:

• amortisation of intangible assets;
• purchase of goods with resale options;
• discounting of dismantling and restoration provisions;
• substitute tax on the revaluation of reserves: the tax liability must be recorded in equity, not in the income statement.

In June 2025, the new OIC 30 on interim financial statements was also published.

These changes apply from 2026 but may be adopted early in the 2025 financial statements.

OIC Not Yet Final

• The new OIC 5 on liquidation financial statements has not yet been finalised (only the 2024 draft is available).

End of COVID Derogations
For 2025 financial statements, the COVID-related derogations no longer apply regarding:

• suspension of depreciation,
• going concern assessment.

Derogation Still Valid for Current Asset Securities
The derogation allowing companies to avoid writing down securities (when there is no permanent impairment) remains valid for 2025 and 2026.

Mandatory: allocate to a non-distributable reserve an amount equal to the avoided impairment.

The draft OIC 12 is open for consultation until 12 March 2026.

Sterilised Losses from 2020
The five-year period for sterilising 2020 losses ends.
Therefore, in 2025 these losses must be addressed (coverage, share capital reduction, etc.).

Tax Updates from Legislative Decrees No. 192/2025
To be considered for the 2025 financial statements:

• new tax rules on the correction of accounting errors;
• extension of the enhanced derivation principle to micro-enterprises.

These provisions apply to financial years starting on or after 1 January 2025.

Disclosure on Public Grants
The rules remain unchanged compared to last year.
The expected repeal of Art. 125-bis of Law 124/2017 has not been confirmed.

Non-Financial Reporting
Sustainability reporting requirements have been simplified at the European level.

Shareholders’ Meetings for Approval of Financial Statements
Until 30 September 2026, simplified procedures may still be used for:

• remote shareholders’ meetings,
• voting without physical attendance.

The tax regime is a personal income tax (IRPEF) incentive for individuals returning to Italy after a period abroad, and working in Italy as employees, self‑employed professionals, or entrepreneurs.
It allows taxation on only a portion of income for a period that varies depending on the case.

How it works (general rules)

• The incentive reduces taxable income (50%, 30%, or 10% depending on the period and eligibility requirements).
• It applies for 5 years, with possible extensions.
• Requirements include:
  • having lived abroad for a certain period (2, 5, 6, or 7 years depending on the specific rule),
  • transferring tax residency to Italy,
  • working mainly in Italy for at least 183 days per year.

 

Which regime applies? Depends on the return date to Italy

 

Returns from 2024 onwards (new regime)

• Exemption: 50%
• Duration: 5 years
• More limited extension (e.g., +3 years) only under specific conditions, such as purchasing a main residence
• Stricter requirements:
  • at least 3 years abroad (increasing to 6–7 years when returning to work for the same employer or group)
  • mandatory to maintain Italian tax residency for 4 years
    → failure to do so triggers full repayment of the tax benefit plus interest
• Under the new regime, the incentive can be combined with other tax benefits (e.g., “researchers and professors” regime)

Maintaining eligibility

To keep the benefit each year, you must:

• be tax resident in Italy,
• work mainly in Italy (≥ 183 days),
• perform actual work activity in Italy.

Failure to meet the conditions → loss of the benefit for that year or full clawback.

Practically how is it applied?

• Employees:
  request application through the employer → reduced taxable base for payroll withholding.
• Self‑employed professionals:
  apply the benefit directly in the annual tax return.
• If the employer does not apply the regime:
  it can be applied when filing the tax return.

Summary

The regime allows taxation of only a portion of income produced in Italy for 5 years (with possible extensions), with different percentages based on the return date:

• 50% (from 2024 under the new rules)