Italy raises its flat tax for new residents to €300,000 a year

Italy's so-called “new residents” regime is nothing new. It is set out in Article 24-bis of the Consolidated Income Tax Act, the TUIR, introduced by the 2017 Budget Law (legge n. 232/2016, article 1, comma 152) and applicable since 1 January 2017. Its principle fits in one sentence: a person who establishes their tax residency in Italy can choose to pay, on all their foreign-source income, an annual flat-rate tax instead of the progressive scale.

What the 2026 Budget Law changes is neither the form of the regime nor its scope: it is its price. Legge n. 199/2025, article 1, commi 25 and 26, raises the amount of the imposta sostitutiva. This is the second revision in less than two years: Decree-Law n. 113/2024, in August 2024, had already raised it.

According to the Agenzia delle Entrate, the new amount applies “to individuals who transfer their tax residency to the territory of the State from 1 January 2026”. The triggering event is therefore neither the date of the election nor that of the tax return: it is the date on which tax residency switches to Italy.

This mechanism has a direct consequence for anyone preparing a move: a transfer of residence that took place before the end of 2025 and a transfer that took place in January 2026 are not subject to the same rate, even if the election is made in the same tax return.

The annual flat-rate tax payable by the main taxpayer rises to €300,000¹. For each family member to whom the effects of the election are extended, the amount is €50,000² per year.

The rate has thus progressed in three stages:

• transfers of residence up to 10 August 2024: €100,000³ per year;
• transfers from 11 August 2024 to 31 December 2025: €200,000⁴ per year;
• transfers from 1 January 2026: €300,000¹ per year.

The flat rate remains a flat rate: it is due whatever the amount of foreign income, which makes it indifferent to the level of wealth above a certain threshold, and all the heavier below it. The break-even point compared with the ordinary scale — whose top marginal rate reaches 43%⁵ — is calculated case by case, and mechanically moves upwards with each increase.

Access to the regime is closed to those who already lived in Italy. The condition set by Article 24-bis is tax non-residence for at least from 9 years⁶ of the ten tax periods preceding the start of the election's validity. A former Italian resident who left for three years is therefore not eligible; a long-standing expatriate is.

Once made, the election is valid for a maximum of 15 years⁷ from the first tax period of validity. It is tacitly renewed from year to year, unless revoked or unless a terminating event occurs.

The regime is elected in the tax return for the tax period in which residence was transferred. There is no mandatory prior approval form.

Before making the election, however, the taxpayer can submit an interpello request to the Divisione Contribuenti of the Agenzia delle Entrate. This route has a practical benefit: it allows the taxpayer to have it confirmed, before committing, that the prior non-residence condition is met and that the income concerned does fall within the scope of the flat tax. The procedures for making, amending and revoking the election, as well as those for payment, are set by an administrative measure of 8 March 2017.

Payment is made in a single instalment, on the due date for the balance of income tax. For a departure from France, the preliminary question remains the same as elsewhere: tax residency must actually be transferred within the meaning of the applicable treaty, failing which the Italian flat tax will come up against continued French taxation.

The main open point concerns earlier electors. The Agenzia delle Entrate page consulted on 26 September 2026 states to whom the new amount applies — transfers from 1 January 2026 — but does not explicitly say what happens to taxpayers who made the election before that date and whose period of validity is still running. The wording used suggests that they keep the rate in force at the time of their transfer; as of that date, we have not found any express position taken by the tax authorities on this point.

The precise list of income excluded from the flat tax is not detailed on the page consulted: we therefore do not reproduce it here. It must be checked in the text of Article 24-bis of the TUIR and in the implementing measures before any decision.

Finally, the frequency of revisions is in itself a factor to take into account: two increases in less than two years, through two successive budget texts, mean that a plan built over fifteen years rests on a rate that the legislature has shown it is willing to change. The amount is locked in for those who have already transferred their residence; it is not for those who are still hesitating.