Italy
The €300k lump-sum tax on foreign income for new residents — a predictable 15-year regime for internationally mobile wealth.
The position in figures.
Headline treatment for an individual tax resident. Source, asset and treaty rules can change the payable result.
Where the jurisdiction fits.
Best for
- HNWIs with substantial foreign-source income relocating after 9 of 10 prior years outside Italy
- Family successions valuing a fixed annual charge and IHT exemption on foreign assets
- Retirees considering the Southern Italy 7% flat regime in towns under 20,000 inhabitants
- Founders post-exit prioritising lifestyle over corporate optimisation
Consider carefully
- Anyone whose income is genuinely Italian — flat tax only covers foreign-source
- Buyers expecting fast administrative processes
- Crypto-active traders — Italian rules tightened in 2023 with a 26% CGT regime above €2,000 of gains
Programmes that matter.
New Residents Lump-Sum Tax (€300k)
Article 24-bis regime: €300,000 annual substitute tax on foreign-source income and gains for new residents from 2026, for up to 15 years. Add €50,000 per qualifying family member. Existing residents are grandfathered at the rate applying when they entered. Foreign assets are exempt from IVAFE/IVIE and from inheritance tax while covered.
7% Pensioners Regime (Southern Italy)
Foreign pensioners moving to municipalities under 20,000 inhabitants in Sicily, Calabria, Sardinia, Campania, Basilicata, Abruzzo, Molise or Puglia: 7% flat tax on all foreign income for 10 years.
Investor Visa (Italia Startup Visa / Investor Visa)
Two-year residence permit, renewable, for €250k startup investment, €500k SME investment, €2M government bond, or €1M philanthropic donation. Independent of tax-flat-tax election.
Pitfalls to resolve early.
- 01
The annual lump sum is €300k for new residents from 2026. Existing users remain grandfathered at the €100k or €200k amount that applied when they entered.
- 02
Foreign-source is interpreted strictly: Italian-source income (employment, rentals, business in Italy) remains fully taxed at standard rates.
- 03
Capital gains on "qualifying" shareholdings (>20% private / >2% listed) realised in the first 5 years are taxed under standard rules, not the flat tax.
- 04
You must have been non-resident for 9 of the previous 10 tax years to qualify.
- 05
Italian tax administration is paperwork-intensive; ruling requests are recommended for material foreign structures.
Direct answers.
How does the Italian flat tax work?
New tax residents who were non-resident for 9 of the last 10 years can elect to pay €300,000 per year on foreign-source income and gains for up to 15 years. Italian-source income remains taxed at ordinary rates.
What changed for the Italian lump-sum tax in 2026?
The 2026 Budget Law raised the annual charge to €300,000 for new residents from 2026 and €50,000 per qualifying family member. Existing residents remain grandfathered at their entry rate.
What is the Southern Italy 7% pensioner regime?
Foreign pensioners moving to a municipality with under 20,000 inhabitants in eight southern regions can elect a 7% flat tax on all foreign income for 10 years. Excellent fit for retirees with foreign pension or investment income.
Does the flat tax cover inheritance tax?
Yes — the regime exempts foreign assets from Italian inheritance and gift tax for the duration of the election, which is materially valuable for large estates.
Can my family join under the flat tax?
Yes — qualifying family members can be added at €50,000 each per year from 2026, covering their foreign-source income and benefiting from the foreign-asset inheritance-tax exemption.
Put Italy against your current position.
See a first-order comparison, then bring the open questions to your advisor.