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Relocation and Life in Italy

Application for the inpatriate tax regime

The inpatriate workers regime is a tax benefit that rewards those who transfer their tax residence to Italy after a period abroad, significantly reducing taxes on income earned in Italy. The legislator, in line with other European systems, uses it to encourage the return of skilled workers, that is, the return of employees and self-employed professionals with high qualifications and specialization, capable of generating value and innovation.

From the 2024 tax year the renewed version introduced by Legislative Decree 209 of 2023 is in force, which redefined requirements, duration, and amount of the benefit. In practice, the worker who correctly submits the application for the inpatriate tax regime obtains a significant reduction of the taxable base of their work income produced in Italy, within precise limits and timeframes.

Boschetti Law Firm supports professionals, managers, researchers, and entrepreneurs in all phases, analysis of eligibility requirements, verification of prior foreign tax residence, preparation of the request to the employer or, for the self-employed, of the documentation to be shown in the tax return, management of exchanges with the Italian Revenue Agency. The goal is simple, to maximize the benefit and prevent the risks of forfeiture, so that moving to Italy is truly advantageous from a tax perspective.

Benefits for those who transfer residence to Italy

With the inpatriate regime, the taxable base of income from work produced in Italy is reduced by half. In some expressly provided cases, the taxable base decreases to 40 percent, so the tax relief rises to 60 percent. The benefit applies up to 600,000 euros of total annual income and lasts five tax periods in total, the year of first application plus four subsequent periods.

Beyond the limit of 600,000 euros, the excess returns to being taxed ordinarily. This framework, also common in other European countries, was designed to make returning to Italy competitive without sacrificing legal certainty and controls.

To benefit from the regime, employees submit a written request to the employer, who applies the relief in the payslip, while the self-employed act through the tax return, keeping documents proving the requirements. The economic rationale is clear, to attract qualified human capital in the medium term, with a timeframe sufficient to transfer skills and stabilize business projects.

It is essential to respect the conditions throughout the five years, because non-compliance removes the benefit, with recovery of taxes and interest. For this reason, careful planning of the return of skilled workers and annual monitoring of requirements are essential to avoid disputes.

Requirements of the inpatriate regime and related advantages

The law identifies four requirements. The first is economic policy, to attract to Italy qualified workers who can contribute to development, in line with the reform introduced by article 5 of Legislative Decree 209 of 2023. The other three requirements are territorial.

First territorial requirement, the applicant must commit to maintaining tax residence in Italy for at least four years. Residence must be interpreted not only under article 2 of the TUIR, as amended by Legislative Decree 209 of 2023, but also in light of treaty clauses on dual residence. If a treaty tie breaker assigns residence to another State, the personal link with Italy ceases and the benefit lapses retroactively, with recovery of tax and interest.

Second requirement, absence of tax residence in Italy in the three years prior to the first application. The minimum period is extended when the return occurs within the same corporate group, or if in the past one has worked in Italy for that same entity, according to the extensions provided by the reform. For Italian citizens, verification of non-residence also considers AIRE registration or foreign residence under treaty rules, as clarified by practice.

Third requirement, the work activity must be carried out in Italy for most of the tax year. In practical terms, the center of the activity must remain on national territory.

If all conditions are met, the advantages are immediate, taxable base at 50 percent, reducible to 40 percent in the cases provided, with an annual ceiling of 600,000 euros and five-year duration. A framework that makes the regime for new residents truly effective, provided it is managed with rigorous documentation and correct interpretation of treaties.

Typical scenarios / Case studies

The typical scenarios have been developed by drawing on the most significant corporate immigration cases that the firm regularly handles, with the aim of creating structured, complex examples that help the reader navigate their own situation. The case studies, by contrast, illustrate individual real-life matters, anonymised to protect client confidentiality, presented with full factual and contextual detail.

Relocation

US professional chooses Italy: elective residence obtained and future planned

American professional obtains an elective residence visa while maintaining ties with the USA. Integrated assistance from legal strategy to property search..

Application completed in approximately 3 months without additional requests
Business

US opera singer obtains work authorization in 7 days

American opera singer with contracts already signed with an Italian theatre. Self employment work authorization obtained on an urgent basis to meet professional commitments.

Work authorization issued within 7 days from submission of the application
Real Estate

US client purchases property in Rome: secure transaction

American client assisted in the purchase of a property in Rome. Urban planning issues and contractual risks identified and resolved before signing, transaction completed through notarial power of attorney.

Purchase completed within one month, entirely managed remotely
Business

American investor: from New York to a villa in Tuscany

Cross-border property transaction with full relocation service. Purchase of a high-end property, with tax status, residency and NHS registration handled remotely.

Complete relocation service, from property due diligence to handing over the keys
Retirement

Canadian couple, retirement property in Puglia

From Toronto to the Itria Valley. Purchase of a farmhouse with cadastral issues, 7% flat tax on foreign pensions, elective residence visa and healthcare transition.

7% flat tax activated, cadastral issues resolved before the deed of sale
Business

British entrepreneur, opening a business in Milan

Post-Brexit, a London-based tech entrepreneur establishes an operational headquarters in Milan. Immigration pathway as a non-EU national, company incorporation, and tax planning.

European operational hub established with self-employment visa successfully obtained
Tax Planning

Swiss retiree: 7% flat tax regime in Southern Italy

A banking executive relocates from Zurich to Calabria. Management of the Swiss occupational pension pillar, Italy-Switzerland Tax Convention, and deregistration from the cantonal tax register.

7% flat tax activated on all foreign-sourced income
Retirement

American couple: retirement project in Abruzzo with visa and flat tax

From Connecticut to Abruzzo. Elective residency visa, 7% flat tax coordinated with IRS and FATCA obligations, and transition from Medicare to the Italian NHS (SSN).

7% flat tax activated on Social Security and 401(k) pension income
Relocation

German couple, from Munich to Tropea

Retired engineers from the Bavarian automotive sector. Multi-tier pension management, Italy-Germany Tax Convention, and the 7% preferential tax regime.

Three German pension pillars optimised with Italian flat tax
Business

Startup tech: apertura filiale italiana per il mercato EU

A Bay Area SaaS company establishes a Milan headquarters. Innovative startup SRL, EU Blue Card for the team, transfer pricing, impatriates tax regime, and GDPR compliance.

Operational within 5 months, payroll cost −35% with impatriates tax regime
Business

Fashion brand, representative office in Milan

Brand premium newyorkese apre presidio a Milano. Strutturazione per evitare stabile organizzazione, trasferimento direttrice creativa e gestione showroom.

Rischio stabile organizzazione prevenuto, presidio EU operativo
Corporate

Manufacturing company, ICT transfers to Italy

Multinazionale giapponese trasferisce 3 figure chiave in Piemonte. Permessi ICT per manager e specialista, coordinamento consolare e regime impatriati per tutti i dipendenti.

3 trasferimenti completati in 4 mesi e mezzo, linea produttiva avviata nei tempi previsti

    How Boschetti International Law Firm can help with the application for the inpatriate tax regime

    Our Firm relies on a team of experts in national and international tax law, and acts as follows:

    • Eligibility pre check, we examine contracts, countries of previous residence, applicable treaties, and group structure, to prevent pitfalls on tie breakers and economic links abroad.
    • Return plan, we define timing and documents for registry office, AIRE, housing, place of activity, in order to stabilize tax residence from the first year.
    • Benefit application, we prepare the request to the employer for employees or the set of documents for the self-employed, aligned with the instructions of the Revenue Agency.
    • Monitoring, we check each year that the requirements remain intact, especially in the case of long assignments, transnational remote working, or change of employer within the group.
    • Variant management, when convenient, we assess coordination with other regimes for attracting new residents, such as the option under article 24 bis TUIR for new residents with foreign income, or the 7 percent retirees regime under article 24 ter. This comparative analysis avoids improper overlaps, optimizes the tax burden, and reduces the risk of litigation.

    We work with documents, deadlines, treaties, and official practice, so that your application for the inpatriate tax regime is consistent, complete, and sustainable over time.

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    Foreign pensioners in Italy: how the 7% flat tax regime works and who can access it

    The 7% flat tax regime allows individuals receiving pensions from foreign entities to transfer their tax residence to a municipality in Southern Italy (with fewer than 20,000 inhabitants) and apply a 7% substitute tax on all foreign-source income for nine tax years.

    Eligible municipalities are located in Sicily, Calabria, Sardinia, Campania, Basilicata, Abruzzo, Molise, and Puglia, as well as certain municipalities affected by the 2009 earthquake. The regime applies to all categories of foreign-source income. The option is exercised in the tax return, indicating the chosen municipality of residence.

    Registered residence in Italy but tax residence abroad: is it possible and what does it imply?

    This is a potentially risky situation. Registration in the Italian population registry creates a presumption of tax residence in Italy, with the obligation to declare worldwide income. This presumption can be rebutted by demonstrating that tax residence is abroad, including through registration with the AIRE or under applicable double taxation treaties, but the burden of proof remains on the taxpayer.

    The Italian Revenue Agency may assess these situations based on objective factors. The presence of personal or economic ties in Italy may affect the determination of tax residence. It is therefore advisable to define one’s tax position in advance and prepare adequate supporting documentation, also considering tools such as advance rulings.

    Health card for foreign nationals with elective residence: how to obtain it and what it covers?

    Foreign nationals holding a residence permit for elective residence may enroll in the Italian National Health Service (SSN) on a voluntary basis, subject to payment of an annual contribution. Enrollment grants access to healthcare services under the same conditions as SSN beneficiaries, including general practitioners, specialist care, and hospital treatment.

    The annual contribution is calculated based on total income and cannot be lower than €387.34. Alternatively, private health insurance may be used, provided it meets the requirements for residence in Italy.

    New residents regime vs inbound workers regime: which is more advantageous and what are the requirements?

    The new residents regime (Art. 24-bis TUIR) provides for a flat tax of €200,000 per year on all foreign-source income, regardless of the amount. The inbound workers regime (Art. 16 of Legislative Decree 147/2015) allows a reduced taxation on employment income produced in Italy. They are designed for different profiles.

    The new residents regime is suitable for individuals with very high foreign income who do not work in Italy. The inbound workers regime is intended for those who move to Italy for work and have not been tax resident there in the previous two years. They are only partially compatible. The choice should be made before relocating.

    Relocation: why are due diligence and real estate advisory crucial before purchasing?

    Because the Italian real estate market presents specific risks that foreign buyers may not be aware of: unauthorized building works not regularized, outstanding mortgages, cadastral discrepancies, landscape restrictions, and undisclosed easements. Technical and legal due diligence carried out before signing the preliminary agreement allows these issues to be identified while it is still possible to renegotiate or withdraw.

    Specialized real estate advisory for foreign clients also includes urban planning checks, verification of systems compliance, independent property valuation, and assistance in negotiations. Purchasing without these checks exposes the buyer to unexpected costs and post-acquisition disputes.

    The ItalyVisaInvestment website is owned by Studio Legale Boschetti and is the go-to resource for foreigners who wish to invest in Italy, obtain elective residence, or apply for an investment visa.

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