Italy’s 2017 Finance Law has introduced a new tax regime designed to compete with the UK “resident but not” domiciled tax regime” that has proved so popular over recent years. The regime is targeted at newly Italian resident high net worth individuals. It requires a lump-sum payment of Euro 100,000 per annum in lieu of income tax at normal rates for individuals. The new rules apply to individuals shifting their residence to Italy in, or after, FY 2017. They exclude non-Italian income and gains from the normal charge, while tax will be due at the usual rates (up to 43% plus local income taxes) on Italian source income and gains. Individuals opting for the regime will also be exempt from the extensive requirements for the tax reporting of foreign income and assets. There is also exemption for the annual wealth taxes on foreign real estate and financial assets (IVIE & IVAFE) and from inheritance on non-Italian assets.
A circular from the Tax Agency has been issued containing implementing procedures – the taxpayer must obtain an advance ruling for admission to the new regime – and containing a form to be submitted to the authorities for confirmation that the regime will apply. Differently from the UK’s regime there will be no ban on actually bringing funds (remittance) from abroad into Italy even where those funds have not been taxed in full. Indeed the intention of the legislator is to foster investment in Italian businesses and assets.