"Regime impatriati": the new rules that apply starting from 2024

The "International Taxation Decree" - Legislative Decree No. 209/2023 - approved in December 2023 changed the facilitative tax regime provided for so-called “impatriates”, i.e. people who transfer their tax residence to Italy from abroad.

This favorable tax regime had been introduced a few years ago by Article 16 paragraph 1 of Legislative Decree 147/2015, however, since 2024 its features have been changed.

For workers who transfer their residence to the Italian territory pursuant to Article 2 of the TUIR - Presidential Decree 917/1986, within the limit of 600,000 Euros per year, income from employment, income assimilated to employment, and self-employment income from the exercise of arts and professions produced in Italy, contribute to the formation of the total income limited to 50% of their amount when certain conditions are met.

Who can benefit from the "impatriates" tax regime?

The benefits under the "impatriates" tax regime apply to workers:

- who transfer their residence to Italy as of January 1, 2024 and maintain it for the 4 periods following the year in which the transfer occurred

- who have not been tax resident in Italy in the 3 tax periods preceding their transfer to Italy. If the employee works in the territory of the State for the same entity for which they were employed abroad before the transfer or for an entity belonging to the same group, the minimum requirement in terms of previous absence from the Italian territory:

• 6 tax periods, if the worker has not previously been employed in Italy in favor of the same entity or an entity belonging to the same group

• 7 tax periods, if the worker, prior to their transfer abroad, has been employed in Italy in favor of the same subject or a subject belonging to the same group

The "impatriates" tax regime is available to Italian, EU and non-EU citizens, provided they meet the above requirements, including the transfer of tax residence to Italy (which in the case of non-EU citizens implies the need to obtain a visa and a residence permit for Italy in advance).

Benefits of adhering to the “impatriates” tax regime

Those who take advantage of the "impatriates" tax regime enjoy a 50% reduction in their total taxable income when the above conditions are met. In addition, those who return to Italy with a minor dependent child will have their exemption rate increased to 60%, and the same increase applies to those who become parents or adopt a minor during the period of benefiting from the "impatriates" tax regime.

Your Way to Italy: our assistance

Our team is available to provide support and assistance throughout the process! Contact us to book your initial consultation and to take advantage of the "impatriates” tax regime! #YourWaytoItaly

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

Article written by Alessia Ajelli, Managing Associate of LCA Studio Legale, Italian lawyer specialized on Italian immigration and citizenship law, and Paolo Grassi, Trainee of LCA Studio Legale.