How does Italy's flat tax on foreign income for new residents work?

Checked on 2026-10-25

Italy's flat tax for new residents (TUIR art. 24-bis) replaces income tax on foreign income with a fixed €300,000 a year, plus €50,000 for each family member included, for people moving from 1 January 2026. You must not have been Italian tax resident in nine of the previous ten years, and need a favourable ruling from the Agenzia delle Entrate.

Key facts

What	The law says	Source
What it covers	Income produced abroad (identified under TUIR art. 165(2))	TUIR, art. 24-bis(1)
How much	€300,000 per tax year, whatever the amount of foreign income	TUIR, art. 24-bis(2)
Family members	€50,000 per year for each family member (under Civil Code art. 433) included	TUIR, art. 24-bis(2) and (6)
From when these amounts apply	People who move their residence to Italy from the entry into force of Law 199/2025 (1 January 2026); the law replaced the previous €200,000 and €25,000	Law 199/2025, art. 1(25)–(26)
Who can opt	People who move their tax residence to Italy and were not Italian tax resident for at least 9 of the 10 tax periods before the option starts	TUIR, art. 24-bis(1)
How to opt	After a favourable reply to a ruling request (interpello) to the Agenzia delle Entrate, by the tax return deadline for the year of the move	TUIR, art. 24-bis(3)
How long	Up to 15 years from the first year; revocable; no new option after revocation or forfeiture	TUIR, art. 24-bis(4)
Payment	In one instalment, by the deadline for the income tax balance (saldo)	TUIR, art. 24-bis(2)
Reporting	No foreign-asset reporting under DL 167/1990, art. 4, and no IVIE or IVAFE while the option is valid	TUIR, art. 24-bis, update note (181) on Law 232/2016, art. 1(153)

What is and isn’t covered

The fixed tax replaces IRPEF on income produced abroad. The law excludes one thing from the flat tax: gains on qualified shareholdings (art. 67(1)(c)) realised in the first five years of the option stay under ordinary taxation.

You can choose to leave out income from one or more countries when you opt or later. That income is then taxed under ordinary rules, with the foreign tax credit (art. 24-bis(5)).

Applying

The law requires a favourable reply to a ruling request (interpello) from the Agenzia delle Entrate. In the option you name the country or countries where you were last tax resident; the Agenzia passes this on to those countries’ tax authorities (art. 24-bis(3)).

Losing the regime

The law ends the option after 15 years, if you revoke it, or if you fail to pay the tax in full and on time. Earlier years are unaffected. After a revocation or forfeiture you can’t opt again (art. 24-bis(4)). Revocation or forfeiture of the main taxpayer also ends it for family members (art. 24-bis(6)).

The option can’t be combined with the earlier returning-worker and impatriate regimes of DL 78/2010, art. 44, and D.Lgs. 147/2015, art. 16 (Law 232/2016, art. 1(154), cited in the update note to art. 24-bis).

Sources

D.P.R. 22 dicembre 1986, n. 917 (TUIR), art. 24-bis, with update notes (text in force, Normattiva) checked 2026-10-25
Legge 30 dicembre 2025, n. 199 (Budget Law 2026), art. 1, commi 25–26 (Normattiva) checked 2026-10-25

Change history

2026-10-25: Page created

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