Relocating to Italy as an international consultant: tax planning and the Impatriati Regime

O.S. (name abbreviated for privacy reasons) is a senior international consultant with over 25 years of experience in strategic consulting and management consulting. His professional career has developed primarily in international contexts, with assignments at multinational companies and consulting projects in various countries.

In recent years the client worked in the United Arab Emirates, also collaborating with a leading international consulting firm, including P…D…, with which he maintained a professional advisory relationship. In 2025 the client decided to relocate permanently to Italy, with the aim of launching his own management consulting practice focused on strategic transformation projects and corporate cost optimisation.

The relocation project envisaged the transfer to Italian territory starting from 2026, with an initial forecast of professional revenues of approximately 100,000 euros per year derived from international consulting assignments.

In order to ensure that the transfer was tax-efficient and compliant with Italian regulations, the client requested preliminary advice from the law firm.

In order to address the project in a structured manner, the IVI team prepared a preliminary tax planning and relocation consultation, divided into several phases, in synergy with a partner tax consultant specialised in the sector.

This approach makes it possible to define in advance the key elements of the transfer, reducing uncertainties and tax risks.

1. Analysis of the international tax position

The first phase involved an in-depth analysis of the client’s personal and professional situation.

In particular, the following were examined:

• the history of the client’s previous tax residencies;
• income received in recent years;
• the structure of professional relationships with clients and international companies;
• documentation relating to physical presence in the United Arab Emirates and existing contractual relationships.

This analysis made it possible to reconstruct the client’s overall tax picture and to assess the prerequisites for the transfer of tax residence to Italy.

2. Verification of access to the impatriati regime

A central part of the consultation concerned the verification of the possibility of accessing the preferential tax regime for impatriati workers.

This regime allows, when certain requirements are met, a significant reduction in the taxable base on income produced in Italy for a certain period of time.

The law firm’s activities included:

• verification of the requirement for tax residence abroad for the period required by the regulations;
• analysis of the nature of the professional activity to be carried out in Italy;
• assessment of the client’s professional qualifications and level of specialisation.

This phase is essential to establish whether the relocation can benefit from significant tax advantages, with a direct impact on the economic planning of the activity.

3. Structuring professional activity in Italy

Alongside the tax assessment, the IVI team analysed the most efficient structure for starting the consulting activity in Italy.

In particular, the following aspects were addressed:

• opening of a VAT number for the exercise of professional activity;
• identification of the correct ATECO code for the management consulting activity;
• definition of the applicable social security and pension framework;
• identification of a specialist accountant for the accounting and tax management of the activity.

The law firm also coordinated the process of selecting the most suitable accounting professional for the client’s needs and the structure of his international activity.

“When planning an international relocation, the tax aspect can become extremely complex. The advice I received allowed me to understand precisely what steps to take before the transfer and how to correctly structure my professional activity in Italy.”