Italy: those who moved before 2026 keep the €200,000 flat tax

Italy's new-resident regime replaces taxation of all foreign-source income with an annual flat tax. Italian-source income, however, remains taxed under the ordinary scale.

The Italian revenue agency dates the steps precisely. For transfers of residence up to 10 August 2024, the flat tax is €100,000¹ per year.

For transfers from 11 August 2024 to 31 December 2025, it is €200,000².

For transfers from 1 January 2026, it is €300,000³.

The flat tax per included family member follows the same stepped logic and is €50,000⁴ for the most recent transfers.

Each increase applies only to taxpayers whose transfer of residence took place after its effective date. Those already admitted to the regime keep the amount in force when they arrived, for the full duration of the option.

This duration is a maximum of 15 years⁵, starting from the first tax period for which the option is valid.

In practice, three Italian residents may today fall under the same scheme while paying three different amounts. The date of transfer is the only parameter that distinguishes them, and its effects last fifteen years.

This structure creates a premium for moving early, and it explains the waves of arrivals observed as each deadline approaches.

It has an obvious practical consequence for a project under way: the year of transfer carries more weight than any other choice, and a delay of a few weeks can change the cost of the regime for a decade and a half.

The limit of this reasoning should nevertheless be stressed: what is secured is the amount, not the access conditions. Nothing prevents the legislator from tightening the conditions for maintaining or renewing the regime in future, and current beneficiaries are not protected from a reform of another kind.

The option is reserved for persons who have not been Italian tax residents for at least from 9 years⁶ out of the ten preceding the transfer.

The flat tax covers foreign income whatever its amount: dividends, interest, rents, capital gains, pensions. It is this flat-rate nature, not a reduced rate, that makes the scheme attractive for large fortunes.

An option exists to exclude certain states, which the taxpayer may choose to leave outside the flat tax, for example to preserve the credit for a foreign tax. This choice is made on entering the regime.

Italian-source income falls under the ordinary scale, whose top marginal rate reaches 43%⁷, plus the regional and municipal surcharges.

We do not publish the details of the state-by-state exclusion mechanism or the list of jurisdictions for which it is worthwhile: they do not appear in the extracts we have been able to verify.

1. Have an adviser fix the exact date of the transfer of residence: it determines the applicable step.
2. Check the condition of from 9 years⁶ of non-residence in Italy over the ten preceding years.
3. Calculate the family flat tax, which is added to the main flat tax for each included person.
4. Isolate Italian-source income, which remains taxed under the ordinary scale.
5. Handle the departure from France according to French criteria: presence of more than 183 days⁸ entails Italian tax residency, but France applies Article 4 B of the French General Tax Code.

Finally, Italian inheritance tax is a separate and rarely highlighted argument: 4%⁹ in the direct line and between spouses, with an allowance of €1,000,000¹⁰ per beneficiary. For estate planning, this parameter weighs more in the long run than the amount of the flat tax itself.