New Tax Regime for Impatriates 2024
The New Facilitation
Starting in 2024, the regime for impatriates has undergone major changes. Workers who transfer their tax residence to Italy can benefit from tax breaks on employment and self-employment income up to €600,000, taxed at 50 percent. The main conditions are:
- Not having been a tax resident in Italy in the previous 3 years.
- Commitment to tax residence in Italy for at least 4 years.
The Reinforced Facilitation
Taxable income is reduced to 40 percent if the worker moves with a minor child or adopts a minor.
The Conditions for Intragroup Transfers
If the return is to a group company, the stay abroad must be at least 6-7 years.
The Requirement for Italian Citizens
For Italian citizens, it is sufficient to have been registered with AIRE or to have residency in another state under a double income tax treaty.
The Requirement of High Qualification or Specialization
This requirement covers both employed and self-employed workers and includes possession of a higher education qualification or high professionalism.
What’s New in Tax Residence
From 2024, those who have their residence or domicile in Italy for most of the tax period, including fractional days, are considered residents.
Facilities for Self-Employed Workers
The Reference to the Exercise of Arts and Professions
The new specifications exclude copyright income.
The Changes to the “De-Minimis” Regime
The limit of €200,000 was increased to €300,000.
The Monitoring of the Facilitation
Self-employed persons must report the benefit in the RE and RS forms of the tax return.
Transitional Scheme for Older Impatriates
The old benefits continue for those who moved residence by Dec. 31, 2023. A transitional scheme is provided for those who move residence in 2024 and purchase a house by Dec. 31, 2023.
Operational Tools
Download facilitation application forms and summary slides:
- Facsimile Application for Facilitation for Self-Employed Workers
- Facsimile Application for Employee Relief
- Summary Slides
Schemes of Synthesis
Conditions | Residence Transfers since 2024 | Residency Transfers from 4/30/2019 to 2023 |
Previous foreign residence | 3 years (6-7 years if for the same foreign subject) | 2 years |
Commitment to maintain residence in Italy | 4 years | 2 years |
Facilitated income - Nature | Income from professional employment and self-employment | Employment, self-employment and business income |
Subsidized income - Magnitude | Annual limit of €600,000 | No limit |
Measure of facilitation | 50% taxable income | Taxable income at 30% (40% with a minor child) |
Duration of the facility | 5 years (5+3 years with property purchase by 12/31/2023) | 5 years (extendable for an additional 5 years) |
Work activity carried out mainly in Italy | The service may be for the same foreign entity or group | No discontinuity with pre-transfer activities required |
Qualification or specialization | High qualification or specialization requirements | Not required |