The 2024 Impatriates Regime for Individuals
Legislative Decree no. 209 of 27 December 2023 was published in the Official Gazette (OG General Series No. 301 of 28-12-2023) and is stated to enter into force from 1 January 2024.
The Decree, an executive measure, was approved by the Italian Council of Ministers pursuant to authority granted by Parliament by Law No. 111 of 9 August 2023. The Law conferred authority on the Italian Government to revise the Italian tax system, within the general principles of European Union and international tax law.
Amongst other things, the Decree, at article 5, implements a “new” beneficial tax regime for Impatriates replacing the former regime but only for post 2023 arrivers.
According to the Decree, the new regime will apply to individuals who are tax resident in Italy, for the first time in the past three to seven years, starting from the Italian tax year ending 31 December 2024 (FY 2024), and who apply to register as resident in Italy on or after 1 January 2024. Individuals already benefitting from the former regime at 31 December 2023, or who are registered as resident in Italy with effect on or before 31 December 2023, will remain on the pre 2024 regime, for the rest of its natural 5 or 10 year term, and will not be impacted by the new rules.
The earlier legislation (Article 16 of Legislative Decree 14 September 2015, no. 147, and Article 5, paragraphs 2-bis, 2-ter and 2-quater, of Decree-Law 30 April 2019, no. 34, converted, with amendments, by Law No. 28 June 2019, no. 58) was abolished, but continues to apply to pre 1 January 2024 arrivers.
This means that the (copious) Tax Agency guidance and jurisprudence relating to the old regime will not necessary apply under the new regime.
Rate of the Relief, Timescale and Earnings Cap
- The Relief post 2024 will apply generally at the rate of 50%. Thus 50% of remuneration will be exempt from taxation, the other 50% will be liable to tax at scale rates applicable to the taxpayer’s relevant total income. This rate substitutes the dual rates of 70% and 90% under the pre-existing regime;
- The Relief will apply for a maximum of five tax periods (generally the calendar year) starting with the first year in which the taxpayer is tax resident in Italy;
- The benefit will be capped at an annual salary of Euro 600,000 – no relief will be available for earnings over that amount;
- The exempt portion of income will rise to 60% for a worker with at least one minor (under age eighteen) child at the time of the transfer to Italy . If the worker has no children at the time of the transfer, in the case of the subsequent birth or adoption of a child, the extra benefit will apply from the tax year in which the child is born or adopted up to the end of the original 5 year period. The child must be tax resident in Italy for the whole of the period in which the tax benefit applies.
Requirement to Work in Italy and Minimum Period to Remain
- The work activity (employment or self employment as a professional) must be carried out for the greater part of the tax period from Italian territory. The relief will not apply to profits from a business activity. The requirement in the original text that the employer be a resident company, appears to have been removed.
- The worker must remain tax resident in Italy for four tax years. If the worker does not remain for the minimum term, they will lose the benefit of the Relief and will need to pay the extra tax due with interest (but not any penalty, it would appear).
Note that there are two separate aspects in the legislation:
- the worker must undertake to remain tax resident for the minimum four tax year period. Making such an undertaking is simple, if you are an employee requesting your employer reduce payroll withholding taxes. It is less clear how this can be accomplished if you are self employed, are not paid through a payroll or if you employer does not wish to reduce the payroll withholding tax.
- in any event the legislation states that the relief is lost if you do fulfill the minimum four year tax period of Italian tax residence.
Minimum Period of Non Italian Tax Residence
Under the 2024 version of the Italian Impatriates Regime, eligibility depends not only on transferring tax residence to Italy, but also on the length of prior non-residence, which varies according to the identity of the employer.
As a general rule, the individual must not have been tax-resident in Italy for at least three tax years prior to the transfer.
However, a longer minimum period applies where the individual returns to Italy to work for:
- the same employer as before the transfer abroad, or
- an employer belonging to the same corporate group as a previous employer.
In such cases, the required period of non-Italian tax residence increases to six tax years.
Where the individual was previously seconded or posted abroad by an Italian employer and then returns to Italy to work for that employer or group, the minimum non-residence period is further extended to seven tax years.
These provisions are anti-avoidance measures to counter people “stepping out” of Italy for a short period returning to get the benefit of the Relief. Careful analysis of the employer relationship is therefore essential when assessing eligibility for the regime.
In practice, the definition of “same group” is interpreted broadly, and taxpayers should assess group relationships carefully before relying on the three-year rule.
Individual Requirements – Education (Professional Qualifications and Experience)
The worker must be in possession of the high qualification or specialisation requirements defined by specific Italian legislation (a minimum three year higher education qualification and higher educational qualification attested by the country of origin and recognized in Italy). This requirement applies alike to Italian citizens, EU blue card holders and non EU citizens legally holding the right to remain within Italian territory). Under the prior regime Italian citizens were not obliged to meet this requirement.
The legislation states the requirement here is either recognition of the professional qualification for “regulated” professions or “a higher education qualification issued by the competent authority in the country where the qualification was obtained certifying the completion of a higher education path lasting at least three years and a related higher professional qualification, falling within levels 1, 2 and 3 of the ISTAT (Italian statistical office classification of the professions CP 2011 and subsequent amendments, certified by the country of origin and recognized in Italy.
In a ruling made in response for a request for official guidance (interpello Risposta n. 55/2025) the Tax Agency make it clear that while it is up to other Italian government departments to assess and certify qualifications and experience, in general terms, the individual must meet at least one of the following conditions:
- Hold a University degree or an equivalent higher education qualification. The qualification must be recognized under Italian or EU academic standards (e.g by requesting a “Dichiarazione di Valore” – see below);
- Work in a regulated profession – for example doctors, lawyers, chartered/certified accountants, engineers, architects etc. The profession must be one of those recognized as regulated under Italian/ EU law, meaning it requires specific licensing or registration with a professional body to practice;
- Demonstrate at least 5 years of high-level experience comparable to a University qualification. The experience must be in a specialized or technical field that would typically require a higher education degree. This criterion applies where formal education is substituted by proven professional expertise. The experience must relate to the work actually to be carried out as specified in an offer or contract of employment;
- A higher professional qualification attested by at least three years of relevant professional experience acquired in the seven years preceding the submission of a EU Blue Card application, as regards managers and specialists in the field of information and communication technologies (“ICT”) referred to in ISCO-08 classification No 133 and No 25. In broad terms this means that that individuals in the ICT sector must have at least 3 years of experience in an ICT managerial or specialist role, involving specialized or leadership responsibilities.
For University Degrees the DoV should be sufficient, for other certifications/qualifications further applications may need to be made to the appropriate Government departments.
How to claim the relief
If you are an employee you should make a written letter of request (self certifying that you meet all the requisites) to your employer, ideally before receipt of your first instalment of annual salary in the first tax year that the relief applies – although adjustment via a future payslip for the same year may be possible.
For those employees who have not presented the letter of request for reduction of tax via the payroll, a refund or tax credit can be generated via the annual tax return. this must be done in the return for the first tax year for which the Impatriates Regime applies.
For the self-employed the benefit can be claimed in the first annual tax return for the first year of tax residence after the transfer to Italy.
Grandfathering
The provisions of the old regime (70% or 90% relief) will continue to apply to those who have succesfully applied to be registered as resident in Italy (with the list of resident population “anagrafe“) on or before 31 December 2023 or, for sportsmen and women, to those who have stipulated the relevant employment contract by that date.
Extension of the initial five year period
The reduced tax regime can be extended for a further three tax years, after the initial five, for those who purchase a residential real estate unit to be used as a main residence on or before 31 December 2023 and, in any case, in the 12 months prior to the transfer of residence.
Our interpretation of the legislation is that in order to get the three year extension an individual:
- must have completed a purchase of real estate on or before 31 December 2023; and
- must be considered tax resident in Italy (under the new rules on tax residence) for FY 2024; and
- must register as resident in Italy no later than 12 months after the purchase of the property.
This interpretation needs to be confirmed by the official guidance.
In the further three year period, taxable income is reduced by 50%.
Professors and Research Workers
The new rules do not impact the existing regime applicable to professors and research workers.
EU State Aid Limitation
According to the Decree the provisions of this article apply in compliance with the conditions and limitations of Regulation (EU) 1407/2013 of the Commission of December 18, 2013 on the application of Articles 107 and 108 of the Treaty on the Functioning of the European Union to de minimis aid, Commission Regulation (EU) 1408/2013 of Commission of December 18, 2013 on the application of Articles 107 and 108 of the Treaty on the Functioning of the European Union to de minimis aid in the agricultural sector, and Commission Regulation (EU) 717/2014 of the Commission of June 27, 2014 on the on the application of Articles 107 and 108 of the Treaty on the Functioning of the European Union to de minimis aid in the fisheries and aquaculture.
This broad statement, which amplifies a similar intention in the previous regulations will be of significant importance to high earning self employed, who will be likely to a maximum tax saving of Euro 300,000 over any three period. It remains to be seen whether the Italian government will implement specific rules limiting the tax benefit for employees – at present there seems no intention in this sense.
Social Security
The exemption is expressed to apply only to income taxes. It does not necessarily apply to statutory social security contributions (pension, healthcare and unemployment benefit) which, for those working under a contract of employment are, according to the authorities, calculated on 100% of remuneration.
In Circular number 52 of 7 June 2023, the Italian Social Security Institute (INPS) has confirmed that for qualifying self employed workers, the social security basis is the same as that the reduced basis used to calculate the income tax – i.e. the reduced basis by virtue of the Impatriates Relief. The Circular makes reference to the former Impatriates Regime, but it is believed that the reduction (50% or 60%) will continue to apply from FY 2024 onward.
If you are working remotely from Italian soil under a contract of employment with a foreign company, the Italian Tax Agency has confirmed (see Interpello Response no. 2/2026) that the Impatriates Regime can apply, if the work is carried on mainly from Italian soil and the conditions generally are met.
However working remotely under a contract of employment from Italian soil requires consideration of the employer’s Italian social security position (as well as a series of other issues). See this post for more information on the ramifications of engaging with employees who will be working from Italian soil.
Wealth Tax
The Impatriates Regime does not provide any exemption from Italy’s foreign asset reporting requirements (Section RW of the annual income tax return) or exemption/reduction of wealth tax generally applicable to people who are tax resident in Italy for any year.
Checklist for Eligibility
The following documents are typically requested by the Tax Agency on audit of eligibility for the regime. It is worthwhile collating these as you start on the regime, and indeed the documentary support may be required by an employer, if you are requesting that income tax via the payroll is being reduced.
- Evidence of non residence in Italy for requisite prior tax periods (e.g. certificate(s) of tax residence issued by foreign authorities, copies of tax returns, annual earnings certification etc.
- Degree certificate;
- Declaration of Value for degree certificate – instructions here: Italian Ministerial website in Italian language – translated version in English;
- Certificate of residence (registration with the (Anagrafe) or confirmation of acceptance of declaration of residence issued by local Comune;
- Documentary evidence of registration with AIRE (for Italian citizens) or tax residence in white list country for requisite tax periods (3 to 7) before the move to Italy;
- Confirmation that transfer of tax residence to Italy should be made in connection with a new employment or self employment to be carried on from Italian soil:
- Confirmation of intention to stay tax resident in Italy for at least four tax periods;
- Confirmation of intention to work for the greater part of each future tax period in which the Relief is to apply from Italian territory;
- Confirmation that earnings will be below the Euro 600k annual limit and tax savings will not exceed EU state aid thresholds in force from time to time.
- Confirmation, if you are working under a contract of employment, that your employer is compliant with their Italian social security obligations
The exact confirmation and evidence in support required will depend on an individual’s particular circumstances. It may be possible to proceed with application of the Impatriates Relief while the supporting documents are being collected, albeit it with the risk of extra tax, penalties and interest, if the individual subsequently turns out not to be eligible.
Legislation and guidance
Legislation
Please refer to our blog post on the pre 2024 regime for a listing of the base legislation and Tax Agency guidance on that regime.
- Legislative Decree no. 209 of 27 December 2023 – Official Gazette (OG General Series No. 301 of 28-12-2023)
- Translation into the English language of the Legislative Decree no. 209 of 27 December 2023
- Tax Agency webpage – old regime
- Tax Agency webpage – new regime
- Legislative Decree 28 June 2012, no. 108 – Attuazione della direttiva 2009/50/CE sulle condizioni di ingresso e soggiorno di cittadini di Paesi terzi che intendano svolgere lavori altamente qualificati. (12G0124)
- Legislative Decree 9 Novembre 2007, no. 206 – Attuazione della direttiva 2005/36/CE relativa al riconoscimento delle qualifiche professionali,
- ISTAT – Nomenclatura e classificazione delle Unità Professionali
Interpelli
These are the responses to an Interpello request in relation to the post 2023 Regime. Earlier Interpelli responses can be found here.
Risposta no. 22/2025 – Focus on the switch from employment to consultancy. Clarifies the “Allungamento” (extension) of the required prior residence abroad when staying within the same “economic perimeter.”
Risposta no. 53/2025 – Moving to the Italian subsidiary of a previous foreign employer. Confirms the stricter 7-year prior residence requirement applies if the worker was employed by that same group in Italy before moving abroad.
Risposta no. 66/2025 – Defining “Highly Qualified.” Discusses the transition to a new employer in April 2025 and confirms that a degree (level 6 EQF) is the primary benchmark for the new regime.
Risposta no. 70/2025 – Clarifies that the regime can be accessed by individuals who have never been resident in Italy before (non-Italian citizens), provided they meet the degree and “work in Italy” requirements.
Risposta no. 71/2025 – Further clarification on educational requirements. Confirms that professional qualifications of at least three years (post-secondary) are considered equivalent to a degree for the purposes of “High Qualification.”
Risposta no. 72/2025 – Addresses the “discontinuity” principle. Argues that even if a worker resigns and is rehired, the “group continuity” rule is checked strictly to prevent people from “resetting” their status just to get the tax break.
Risposta no. 74/2025 – Clarifies that the 50% exemption (and the €600,000 cap) applies to the sum of employment and self-employment income if a worker has both.
Response no. 2/2026 – Regime for ‘Impatriated’ workers – access to special regime by a taxpayer returning from abroad, performing their work under contact of employment which envisaged working remotely and which was governed by Italian law incorporating the terms of the relevant CCNL with a company resident in Germany.