Italy opens its doors to HNWI who can move to Italy for tax purposes by paying a flat tax on income produced abroad.
With the decision of the Director of the Revenue Agency of 8 March 2017, the provision of Article 1, paragraph 152, of Law no. 232 of 11 December 2016 (Budget Law 2017), which included Article 24-bis in the Tuir, was made operative.
In essence, in order to encourage investment, consumption and the rootedness of households and individuals with high potential in Italy by non-residents, a special tax regulation is introduced, as an alternative to the ordinary one, reserved to individuals who transfer their tax residence to the territory of the State.
The regime allows for the payment of a substitute tax on the income of individuals with regard to income produced abroad, with the exception of capital gains from the sale of qualified shareholdings in foreign entities, realised within five years of the transfer to Italy. The optional tax regime may be extended to the family members of the applicant specified in Article 433 of the Italian Civil Code, provided that the aforementioned family members transfer their residence to Italy and pay the tax for residents not domiciled in Italy.
The amount of the substitute tax is 100 thousand euros for each tax year to which the above option refers and 25 thousand euros for each of the family members to whom the effects of the option are extended.
The measure clarifies many aspects of the relief, making it fully operational.