Tax Relief for Returning Researchers in Italy: The Stronger Alternative to the New Impatriate Regime
In recent years, Italy’s tax regime for impatriate workers has been progressively reduced in scope.
From 2024, the new framework introduced lower benefits, income limits, stricter timing conditions and a much lower exemption percentage compared with the previous regime.
However, another special regime has remained highly competitive and, in many cases, may now be a more powerful tax planning solution: the regime for professors and researchers under Article 44 of Decree-Law no. 78/2010.
For individuals working in academia, science or research, this regime may allow a 90% exemption on income produced in Italy, with no income cap and a possible extension up to 13 tax periods.
Why the researchers regime is often better than the impatriate regime
The reform introduced by Legislative Decree no. 209/2023 reduced the ordinary impatriate exemption to 50%, or 60% in certain family situations, and introduced a maximum eligible income threshold of EUR 600,000 per year.
The professors and researchers regime remains significantly more attractive for academic and scientific profiles.
- it provides a 90% income exemption;
- it does not provide for a maximum eligible income cap;
- it applies to both employment income and self-employment income;
- it may last up to 13 tax periods;
- it remains highly competitive in an international context.
In practice, a researcher earning EUR 150,000 per year may be taxed on only EUR 15,000 of taxable income, provided that all requirements are met.
Who can access the regime
The regime is reserved for individuals carrying out qualified research or teaching activities who transfer their tax residence to Italy to perform their activity in Italy.
It may apply to:
- university professors;
- researchers;
- research fellows;
- scholars and scientific research professionals;
- individuals carrying out qualified academic or scientific activities.
It is not enough to be generally classified as a highly qualified worker. The link with research or teaching activities must be clear and properly documented.
Main requirements
Access to the regime requires simultaneous compliance with several requirements. These should be reviewed before relocation, because contractual or documentary mistakes may jeopardise the entire benefit.
| Requirement | Practical content |
|---|---|
| University degree | The taxpayer must hold a university degree or equivalent qualification. For foreign degrees, equivalence documentation or a declaration of value may be required. |
| At least two years of foreign research or teaching | The taxpayer must have carried out documented research or teaching activity abroad for at least two continuous years at universities, public or private research centres or qualified scientific organisations. |
| Transfer of tax residence | The taxpayer must transfer tax residence to Italy under Article 2 of the Italian Income Tax Code. |
| Activity carried out in Italy | The research or teaching activity must be carried out in Italy and the eligible income must be connected with that activity. |
| Maintenance of Italian tax residence | The benefit requires the taxpayer to maintain Italian tax residence during the relevant relief period. |
The issue of contracts with foreign institutions
One of the most delicate areas concerns researchers who relocate to Italy while maintaining contracts with foreign universities or institutions.
This often occurs with:
- US universities;
- international research centres;
- scientific foundations;
- organisations such as the Smithsonian, NIH, CERN or similar institutions;
- foreign-funded grants or research projects.
In these cases, the structure must be reviewed carefully. The income should be fiscally connected with the Italian system and the research activity should have an effective link with the Italian territory.
A direct contract with a foreign entity, without an Italian structure, an Italian withholding agent or an operational link with Italy, may create audit risks.
Correct structures for applying the benefit
In practice, the most robust solutions are generally three.
Contract with an Italian university or research body
This is the most straightforward structure. The Italian university or research centre hires the researcher, may receive foreign funds or grants, acts as withholding agent and applies the tax benefit directly.
Self-employment collaboration with an Italian client
The researcher may work as a self-employed professional or scientific consultant for an Italian client. In this case, withholding tax and the taxable base may be determined by taking into account the 10% taxable portion, if the regime is correctly applicable.
This structure is often used in international research projects where scientific coordination remains abroad but the activity is carried out in Italy through an Italian counterparty.
Italian Employer of Record
Some foreign institutions use an Italian Employer of Record. The researcher is formally employed in Italy, payroll and social security are managed locally and the EoR applies the preferential regime.
Even in this case, it is essential to show that the scientific activity has an effective connection with Italy and that the structure is not merely formal.
How long the benefit lasts
The ordinary duration of the regime covers the tax period in which the individual becomes tax resident in Italy and the following five tax periods, for a total of six tax periods.
The duration may be extended in the presence of specific family or real estate conditions.
| Total duration | Condition |
|---|---|
| 6 tax periods | Ordinary duration |
| 8 tax periods | At least one minor or dependent child, or purchase of a residential property in Italy within the applicable timeframe |
| 11 tax periods | At least two minor or dependent children |
| 13 tax periods | At least three minor or dependent children |
No income cap
One of the most important features of the regime is the absence of a maximum income threshold.
This makes the regime particularly powerful for:
- international university professors;
- senior researchers;
- scientists;
- biotech professionals;
- R&D managers;
- AI, deep tech and life sciences specialists with a scientific profile.
For these individuals, the difference compared with the new impatriate regime may be significant, especially where compensation is high or the activity combines research, scientific consulting and international projects.
Compatibility with the new impatriate regime
Recent practice has opened the possibility of an objective combination between the professors and researchers regime and the new impatriate regime, where the two regimes apply to different income streams and genuinely separate activities.
In practice, research or teaching income may benefit from the 90% exemption, while other separate professional income may potentially benefit from the impatriate regime, provided that the relevant requirements are met.
This approach requires careful implementation. It is essential to maintain:
- contractual separation;
- accounting separation;
- a genuine distinction between the activities;
- consistency between the assignment, invoicing and income benefiting from the relief.
Documentation to prepare
Proper documentation should be prepared before the activity starts in Italy.
Key documents include:
- university degrees and equivalence documentation for foreign degrees;
- certifications from the foreign institution;
- contracts and engagement letters;
- evidence of research or teaching activity carried out abroad for at least two years;
- documentation supporting the transfer of tax residence to Italy;
- agreements with Italian universities, research bodies or clients;
- self-declaration to the Italian withholding agent;
- separate accounting documentation where multiple activities are carried out.
In practice, many challenges arise from incomplete documentation or incorrectly structured contracts.
Conclusions
The Italian regime for professors and researchers is currently one of the most effective and stable preferential tax regimes available in Italy for highly qualified human capital.
Unlike the new impatriate regime, it maintains a 90% exemption, does not provide for an income cap and may last up to 13 tax periods.
However, precisely because the tax advantage is substantial, the relocation, contracts, income flows and supporting documentation must be structured correctly.
Incorrect planning may jeopardise the entire benefit.
Taxdry assists researchers, university professors, scientific professionals and international institutions with the tax structuring of relocations to Italy, the preparation of supporting documentation and the operational management of the preferential regime.
