New Residents
Lump-sum taxation
Moving to Italy: the new residents tax regime
A special lump-sum tax regime for individuals relocating to Italy
Italy offers a special tax regime for individuals who transfer their tax residence to Italy after a prolonged period of residence abroad.
Under the regime, qualifying foreign-source income can be subject to a fixed annual lump-sum tax, rather than ordinary Italian income taxation.
For individuals transferring their residence to Italy from 1 January 2026, the lump-sum tax is €300,000 per year, irrespective of the amount of qualifying foreign income.
The regime can apply for up to 15 tax years and can also be extended, subject to the relevant conditions, to qualifying family members.
The regime at a glance
The main features of the Italian new residents regime.
Who can qualify?
The regime is available to individuals who transfer their tax residence to Italy and who have not been Italian tax residents for at least nine of the ten tax years preceding the year in which the option becomes effective.
Your residence history should therefore be considered before the move to determine whether the relevant conditions are satisfied.
The €300,000 lump-sum tax
For individuals transferring their residence to Italy from 1 January 2026, qualifying foreign-source income can be covered by a fixed annual lump-sum tax of €300,000.
The amount is fixed irrespective of the amount of qualifying foreign income received during the year.
Italian-source income remains subject to the ordinary Italian tax rules.
Up to 15 tax years
The regime can apply for a maximum of 15 tax years.
The option is generally renewed from year to year while the applicable conditions continue to be met. It can be revoked and certain events can result in its termination or loss.
Once the maximum period has expired, the regime cannot be renewed.
Qualifying foreign-source income
The lump-sum tax can apply to qualifying income considered to arise outside Italy.
Depending on the circumstances, this may include income from foreign property, investments and financial assets, foreign companies and other activities or assets situated outside Italy.
The distinction between foreign-source and Italian-source income is therefore an important part of the analysis before moving to Italy.
Would you like to discuss your move to Italy?
We can arrange a complimentary and confidential introductory call to understand your circumstances and the professional assistance you may require. Where appropriate, we can introduce you to experienced tax and legal professionals, trustees and family offices whose professional standing and experience have been independently referenced by reputable sources.
There is no charge for this initial conversation.
Family members
The option can, subject to the applicable conditions, be extended to qualifying family members who also transfer their tax residence to Italy.
For family members transferring their residence from 1 January 2026, the annual lump-sum tax is €50,000 for each family member included in the regime.
Each family member must independently satisfy the relevant residence requirements.
Foreign assets
During the period in which the regime applies, qualifying taxpayers benefit from important exemptions in relation to foreign assets covered by the regime.
These include exemptions from certain Italian foreign asset reporting requirements and from IVIE and IVAFE, the Italian wealth taxes applicable respectively to foreign real estate and certain foreign financial assets.
Specific rules and exceptions can apply, so the treatment of foreign assets should be reviewed as part of the overall pre-move analysis.
Choosing which countries to include
The regime offers an important degree of flexibility. It is possible to exclude one or more foreign countries or territories from the lump-sum tax regime.
Income arising in an excluded country is instead subject to the ordinary Italian tax rules and, where the relevant conditions are satisfied, foreign taxes paid may qualify for an Italian foreign tax credit.
This can be particularly relevant for individuals with substantial income, investments or business interests in several jurisdictions.
Inheritance and gift tax
The new residents regime can also provide an important benefit in relation to Italian inheritance and gift tax.
For inheritances and gifts occurring while the relevant option is in force, Italian inheritance and gift tax is generally limited to assets and rights situated in Italy.
Subject to the applicable conditions, assets and rights situated outside Italy can therefore fall outside the scope of Italian inheritance and gift tax during the period in which the option applies.
For individuals and families with assets in several countries, succession and estate planning should therefore form part of the analysis undertaken before transferring residence to Italy.
Before moving to Italy
The new residents regime can be particularly attractive for individuals with substantial income or assets outside Italy, but the lump-sum tax alone should not determine the decision to move.
Before transferring tax residence, it is important to understand where your income will be considered to arise, how your investments and business interests will be treated and whether particular countries should be included in or excluded from the regime.
Foreign property, company interests, investments and other structures may need to be considered, together with the position of family members and any succession or estate planning requirements.
The interaction between the Italian rules and the tax system of the countries in which your income and assets are located can also be significant.
The analysis should therefore begin before, rather than after, you establish tax residence in Italy.
Would you like to discuss your move to Italy?
We can arrange a complimentary and confidential introductory call to understand your circumstances and the professional assistance you may require.
Where appropriate, we can introduce you to experienced tax and legal professionals, trustees and family offices whose professional standing and experience have been independently referenced by reputable sources.
There is no charge for this initial conversation.
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Moving to Italy | Tax & Relocation Guidance
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