Tax Regimes · Art. 24-bis TUIR
Italy's Flat Tax for New Residents
One fixed annual payment covering all foreign income, for up to 15 years. Here is how the regime works in 2026 — including the new €300,000 amount and who is grandfathered at €200,000 or €100,000.
Disclaimer: This page is a general summary and not legal or tax advice. Figures were last verified in July 2026 against the consolidated text of art. 24-bis TUIR as amended by the Budget Law 2026 (Law 199/2025). Obtain tailored advice before relying on any regime.
01
What Is the Italian Flat Tax Regime?
Article 24-bis of the Italian Tax Code (introduced by Law 232/2016) lets qualifying individuals who move their tax residence to Italy pay a fixed annual substitute tax on all foreign-source income, however large. The substitute tax replaces ordinary progressive taxation (IRPEF, 23%–43%) on that foreign income, along with the IVIE/IVAFE wealth taxes on foreign assets and, in general, foreign-asset reporting obligations.
Whether your foreign income is €1 million or €20 million a year, the Italian tax on it stays fixed. Italian-source income — including rent and capital gains from Italian property you acquire — remains taxed under the ordinary Italian tax framework.
02
How Much Does It Cost in 2026?
The amount depends on when you transfer your registered residence (art. 43 of the Civil Code) to Italy — not on when you exercise the option:
| Residence transferred to Italy | Annual substitute tax | Per family member |
|---|---|---|
| Before 10 August 2024 | €100,000 | €25,000 |
| 11 Aug 2024 – 31 Dec 2025 (D.L. 113/2024) | €200,000 | €25,000 |
| From 1 January 2026 (Budget Law 2026, L. 199/2025) | €300,000 | €50,000 |
Existing electors are fully grandfathered at their original amount for the remainder of their 15-year window. The tax is paid in a single instalment by the ordinary income-tax balance deadline (generally 30 June).
03
Who Qualifies?
- — 9-of-10-years test — you must not have been an Italian tax resident for at least 9 of the 10 tax years preceding the election.
- — Italian tax residency — you must become an Italian tax resident (art. 2 TUIR: registration, habitual abode, or centre of vital interests for most of the year).
- — Election — in the first Italian tax return, or through an advance ruling (interpello) to the Agenzia delle Entrate for certainty before relocating.
Family members (art. 433 c.c.) can join for €50,000 each per year (new 2026 entrants), provided each independently satisfies the 9-of-10-years test. Capital gains on qualified shareholdings realised in the first five years remain ordinarily taxed.
04
Is It Still Worth It at €300,000?
The arithmetic is simple: the regime pays off when the ordinary Italian tax on your foreign income would exceed the fixed amount. At the 43% top IRPEF rate, the indicative break-even for new entrants sits around €700,000 of foreign income per year — below that, ordinary taxation (possibly combined with the 7% pensioner regime or the impatriate regime) may be more efficient.
The regime also carries non-arithmetic benefits — exemption from foreign-asset reporting, inheritance and gift tax protection on foreign assets, CFC-rule relief — that weigh heavily for complex estates. For US citizens, worldwide US taxation continues regardless: coordinated dual-jurisdiction planning is essential. Read our full flat-tax analysis for the mechanics in depth, or compare Italy against Portugal and Spain.
Planning a Move
Structure Your Relocation Before You Move
Tax elections must be made correctly and on time — and residence timing now determines your cohort. We coordinate legal and tax planning before you become an Italian resident.
Frequently Asked Questions
How much is Italy's flat tax in 2026?
€300,000 per year for individuals who transfer their registered residence to Italy from 1 January 2026 (Budget Law 2026, Law 199/2025), plus €50,000 per included family member. Those who moved between 11 August 2024 and 31 December 2025 pay €200,000; those who moved before 10 August 2024 keep the original €100,000.
Who qualifies for the Italian flat tax regime?
Individuals who have NOT been Italian tax residents for at least 9 of the 10 tax years before the election, and who become Italian tax residents. There is no minimum wealth or income requirement, and no nationality restriction.
What income does the flat tax cover?
All foreign-source income — dividends, interest, capital gains, rental income, trust distributions, foreign pensions — regardless of amount. Italian-source income (including rent and gains from Italian property) remains taxed under ordinary Italian rules.
How long does the regime last?
Up to 15 years from the first year of validity. It can be terminated voluntarily at any time; once revoked or forfeited, it cannot be elected again.
Does the flat tax exempt foreign assets from Italian wealth and inheritance taxes?
Broadly yes while the regime is active: foreign assets are generally outside Italian inheritance and gift tax, and the regime shields foreign income from IRPEF. Italian-situs assets remain fully subject to Italian taxes.
Can US citizens use Italy's flat tax?
Yes, but the US continues to tax citizens on worldwide income, and the interaction between the Italian substitute tax and the US Foreign Tax Credit requires planning with advisors qualified in both jurisdictions before the move.