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

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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.