Impatriates: less tax for those coming to Italy
New impatriate regime approved by decree Dec. 27, 2023 , No. 209 is effective as of Dec. 29, 2023.
Impatriate workers, whether employees or self-employed, from the 2024 tax period, will be able to enjoy a new facilitated regime for a maximum period of five years (+3 in certain cases).
The new rules stipulate that for those who transfer residence to Italy from 2024 and receive employment income or self-employment income for activities carried out mainly in Italy, the tax base is 50 percent.
The percentage is reduced to 40 percent if the worker moves to Italy with a minor child who maintains residence for the years of the duration of the benefit.
For individuals who move residence to Italy in 2024, the 50 percent (not 40 percent) taxable basis relief applies for an additional three years if the taxpayer has become the owner, by December 31, 2023, and, in any case, in the 12 months prior to the transfer, of a residential real estate unit used as a principal residence in Italy.
Conditions for access:
(a) workers commit to tax residence in Italy for at least 4 years;
- b) the workers have not been tax resident in Italy in the previous three tax periods (the years are longer if the worker works in Italy for the same principal for whom he worked abroad);
(c) the work activity is performed for most of the tax period in the Italian territory (it will be necessary to be able to prove);
(d) the workers meet the requirements of high qualification or specialization (note *)
Limits of the benefit
The reduction applies limited to an annual income of €600,000.
In addition, the de minimis limit Regulation (EU) 1407/2013 applies: the benefit cannot exceed €300,000 in three years.
Example: annual income of 200,000;
estimated average ordinary taxation 79,000
reduction in taxable income to 100,000
estimated ordinary average taxation on the reduced taxable income 35,900
annual benefit 43,100
This advantage also extended to three years does not exceed the EU limit of 300,000 over the three-year period.
(*) As defined by Legislative Decree 108/2012:
(a) the higher education qualification issued by competent authority in the country where it was obtained attesting to the completion of a higher education course of at least three years' duration and the relevant higher professional qualification, as falling within levels 1, 2 and 3 of the ISTAT classification of professions CP 2011 and subsequent amendments, attested by the country of origin and recognized in Italy;
(b) or the requirements set forth in Legislative Decree No. 206 of November 6, 2007, limited to the practice of regulated professions.
