LumenHow does Italy's impatriate tax regime work and who qualifies?
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Under Italy's impatriate regime (Legislative Decree 209/2023, art. 5), only 50% of employment and professional income produced in Italy counts for tax, up to €600,000 a year, for the year you move and the next four. You must not have been Italian tax resident in the previous three years, must be highly qualified, and must work mostly in Italy.
Key facts
| What | The law says | Source |
|---|---|---|
| Income covered | Employment income, income assimilated to it, and self-employment income from arts and professions, produced in Italy | D.Lgs. 209/2023, art. 5(1) |
| How much is taxed | 50% of that income counts towards total income | art. 5(1) |
| Annual cap | €600,000 of income a year | art. 5(1) |
| Time abroad before the move | Not Italian tax resident in the 3 tax periods before the move; 6 if you work for the same employer or group as abroad; 7 if you also worked for them in Italy before leaving | art. 5(1)(b) |
| Qualification | High qualification or specialisation as defined by D.Lgs. 108/2012 and D.Lgs. 206/2007, or research in artificial intelligence technologies | art. 5(1)(d) |
| Where you work | Mostly in Italy during the tax period | art. 5(1)(c) |
| How long | The tax period of the move and the 4 following | art. 5(3) |
| Leaving early | If you don’t keep Italian tax residence for at least 4 years, you lose the benefit and must repay it with interest | art. 5(3) |
| With children | 40% instead of 50% if you move with a minor child, or a child is born or adopted during the regime; the child must live in Italy | art. 5(4)–(5) |
Who it is for
The law applies this regime to workers who move their tax residence to Italy from tax year 2024 onward. You must commit to stay tax resident in Italy for the required period, must not have been Italian tax resident for the three previous tax years (longer if you keep working for the same employer or group), must carry out your work mostly in Italy, and must have a high qualification or specialisation, or have done research in artificial intelligence.
For Italian citizens, the law says that for tax years before the decree they count as having lived abroad if they were registered in AIRE (the registry of Italians resident abroad) or were resident in another country under a double tax treaty (art. 5(6)).
What you get
Only half of your qualifying Italian work income, up to €600,000 a year, is added to your taxable income; the other half is not taxed. If you move with a minor child, or have or adopt a child during the regime, only 40% is taxed, as long as the child lives in Italy.
The old regime
The law repealed the previous impatriate regime (art. 16 of D.Lgs. 147/2015) but keeps it for people who moved their registered residence to Italy by 31 December 2023 (art. 5(9)). People who moved in 2024 and bought a main home in Italy by 31 December 2023, within the 12 months before the move, get three more years at 50% (art. 5(10)).
Related questions
- The regime applies within the EU de minimis state-aid limits of Regulations 1407/2013, 1408/2013 and 717/2014 (art. 5(7)).
Sources
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