Italy flat-tax 2026: what the €300,000 new-resident rate means for HNWI investors

Art. 24-bis was introduced by the 2017 Budget Law (L. 232/2016) as a fixed substitute tax on foreign-source income for qualifying new Italian tax residents. The headline figure has increased twice since then.

Source: Italy Gazzetta Ufficiale, Legge 30 dicembre 2025, n. 199 (25G00212), art. 11.

The underlying benefit — a single flat charge on all foreign-source income, with no obligation to itemise or file a separate foreign-income schedule — has not changed. What has changed is the cost of access for new movers from 1 January 2026.

One question follows naturally from that rate history: could the rate rise again? For anyone electing from 2026, the grandfathering clause in L. 199/2025 locks the rate at the figure in force when the election is first made. Your elected rate, once chosen, is protected for your 15-year window. Whether future Budget Laws alter the rate for subsequent cohorts is a matter of Italian legislative policy, not something any adviser can guarantee today.

The art. 24-bis election replaces ordinary IRPEF (Italy's personal income tax) on foreign-source income with a fixed annual lump-sum charge. For taxpayers who qualify and elect from 1 January 2026 onward:

• Rate: €300,000 per year, payable as a lump sum with the annual IRPEF return.
• Scope: all categories of foreign-source income, regardless of amount or type.
• No foreign-income itemisation required: the flat charge replaces the ordinary IRPEF liability on foreign income for that year; no separate schedule is required for foreign dividends, gains, rental income, or other foreign receipts.
• Maximum duration: the election may be maintained for up to 15 tax periods from first election. The clock starts in the year the election is made.
• Revocability: the taxpayer may revoke the election at any time. Once revoked, the election cannot be re-entered.

The regime does not apply to Italian-source income. Salary earned in Italy, Italian business income, Italian rental income, Italian dividends, and Italian capital gains remain subject to ordinary IRPEF rates and rules. The art. 24-bis election changes the tax treatment only of income sourced outside Italy.

Eligibility for art. 24-bis requires two cumulative conditions.

Condition 1 — the non-residence test. The applicant must not have been an Italian tax resident for at least nine of the ten tax years immediately preceding the year in which the election takes effect. A person who was Italian tax resident in two or more of those ten prior years does not qualify.

Italian tax residence is determined under the standard TUIR rules: a person is considered Italian tax resident for a calendar year if, for the majority of that year, they are (a) registered in the municipal register of resident population (Anagrafe della popolazione residente), or (b) have their habitual abode (dimora abituale) in Italy, or (c) have their civil domicile (domicilio) in Italy. Presence in any one of those registers or factual tests for the majority of the year is sufficient to establish Italian tax residence for that year.

Condition 2 — transfer of civil residence to Italy. The taxpayer must transfer their civil residence to Italy (art. 43 of the Italian Civil Code) in the year for which they first make the election.

There is no nationality restriction. Non-EU nationals, US citizens, and other non-EU/EEA individuals may qualify, subject to the non-residence test and any applicable treaty provisions. Employment or business activity in Italy is not required, nor is any minimum asset threshold.

The scope boundary is the key question for any HNWI considering this regime. It determines whether electing art. 24-bis actually reduces your Italian tax burden — or simply replaces one complex liability with a fixed one.

Income covered by the flat charge (foreign-source only):

• Dividends from non-Italian companies
• Interest on non-Italian accounts, bonds, and financial instruments
• Capital gains from the disposal of non-Italian assets
• Rental income from property located outside Italy
• Employment income sourced outside Italy
• Business or professional income sourced outside Italy

Income not covered — subject to ordinary IRPEF:

• Italian-source employment or business income
• Italian-source professional fees
• Italian-source rental income
• Dividends and capital gains from Italian companies and Italian-sited assets

Also excluded from the flat charge:

• Income from jurisdictions appearing on Italy's list of tax-privileged territories (paradisi fiscali): such income is subject to ordinary IRPEF treatment even if the taxpayer has elected art. 24-bis. The blacklist is updated periodically by Ministerial Decree.

IMU (municipal property tax): the art. 24-bis election does not cover or offset IMU. IMU is a separate Italian local tax levied on the ownership of real estate in Italy, calculated on the cadastral value. The primary residence (abitazione principale) is generally exempt from IMU; non-primary residences and investment properties are subject to it. The IMU rate and any available deductions depend on the municipality and the property classification.

Succession and estate: the flat-tax election does not modify the application of Italian succession tax to Italian-sited assets, nor does it automatically resolve the treatment of foreign estates under Italian private international law. These are separate legal and tax questions requiring dedicated professional advice.

For any adviser fielding an Italian flat-tax question, one thing matters above the rest: when did — or will — the client establish Italian tax residence?

L. 199/2025 includes a grandfathering clause that preserves the rate that applied when a taxpayer first elected. Taxpayers who established Italian civil residence and made their election by 31 December 2025 are not required to pay the new €300,000 rate. They continue under the rate in force at election for the remainder of their 15-year window:

• Pre-August 2024 cohort: elected at €100,000/year (+ €25,000 per family member). Rate is locked for the remainder of the original 15-year window.
• August 2024 – 31 December 2025 cohort: elected at €200,000/year (+ €25,000 per family member). Rate is locked for the remainder of their 15-year window.
• From 1 January 2026 onward: €300,000/year (+ €50,000 per qualifying family member joining the election).

The new €300,000 figure does not apply retroactively to pre-2026 elections. No additional action or notification is required to preserve the grandfathered rate — it follows automatically from the date the election was originally made.

Simplified decision framework:

Did you establish Italian civil residence (art. 43 c.c.) on or before 31 December 2025  
AND make an art. 24-bis election for that year or a prior year?  
  
  YES -> Your election rate is grandfathered:  
         If you elected before 11 August 2024:      €100,000/yr + €25,000/yr per family member  
         If you elected from 11 August 2024 onward: €200,000/yr + €25,000/yr per family member  
  
  NO  -> If you elect from 1 January 2026 or later: €300,000/yr + €50,000/yr per family member  

For taxpayers considering a move to Italy from 2026 onward, there is no mechanism to lock in a prior rate. The €300,000 figure is the baseline for any new election.

The exact date on which civil residence is established — whether it falls in 2025 or 2026 — is the difference for borderline cases. Get specialist advice on the registration mechanics and supporting documentation before committing.

Art. 24-bis allows the main taxpayer to extend the regime to qualifying family members (familiari under art. 433 of the Italian Civil Code), which includes the spouse, children, parents, and certain other dependants. Each family member joining the election must:

1. Transfer their own civil residence to Italy.
2. Satisfy the same non-residence test independently (nine of the ten prior tax years not Italian tax resident).
3. File a separate election in their own IRPEF return for the year of transfer.

From 1 January 2026, the additional substitute-tax charge per qualifying family member joining the election is €50,000 per year (increased from €25,000 under elections made before 1 January 2026).

Illustrative cost — new election from 1 January 2026:

This is a framework illustration only, not a tax calculation. Actual liability depends on individual eligibility, election year, and treaty position.

Annual tax return route

The election is made in the annual IRPEF return (Modello Redditi PF) for the first year of Italian tax residence. There is no separate form, no advance authorisation, and no filing deadline other than the ordinary IRPEF return deadline for that year. On revocation, no penalty applies, but the election cannot be re-entered.

Optional advance-ruling route (interpello preventivo)

Art. 24-bis also permits an optional advance ruling under art. 31-ter of the Statute of Taxpayers' Rights (L. 212/2000). The interpello preventivo (also called interpello sui nuovi investimenti) allows the taxpayer to file a formal request with the Agenzia delle Entrate's International Rulings Office (Ufficio Accordi Preventivi e Controversie Internazionali, Rome) to obtain a binding ruling confirming eligibility before making the election.

The ruling process involves:

• Detailed documentation of the applicant's prior residence history (addresses, days in each country, domicile indicators) for each of the ten prior tax years.
• Disclosure of the sources and nature of foreign income.
• Analysis of any applicable tax-treaty positions.

The interpello route is recommended for taxpayers with complex prior residence histories, US citizenship or other worldwide-tax obligations, or substantial Italian-source income that may complicate the scope boundary analysis. It provides binding certainty before the election is committed and reduces the risk of assessment disputes.

The art. 24-bis election does not switch off United States worldwide taxation.

US citizens resident in Italy remain subject to US federal income tax on worldwide income, regardless of whether they have elected the Italian flat-tax regime. The election reduces the Italian IRPEF liability on foreign-source income to a fixed €300,000/year — it does not reduce or eliminate the parallel US federal tax obligation on the same income.

For a US taxpayer, the value lies in what the election does on the Italian side: it replaces a potentially large and itemised IRPEF liability on foreign income with a predictable fixed charge, removes the obligation to file a detailed foreign-income schedule with the Italian authority, and provides tax certainty for planning purposes. Whether that Italian-side simplification and certainty is worth €300,000 per year depends on your foreign-income quantum and structure — a question your advisers can model before you commit to the election.

The interaction between art. 24-bis and the US foreign tax credit (FTC) is fact-specific and legally unsettled in certain respects:

• Whether the Italian fixed substitute charge qualifies as a creditable tax under the US FTC rules (which require a tax to be a levy on net income to be creditable in full) depends on analysis that is beyond the scope of this guide.
• Treaty-limitation clauses, the character of income under both regimes, and anti-abuse provisions can affect the outcome.
• The US annual foreign-earned income exclusion (Form 2555) applies to earned income but does not eliminate the US liability on investment income, capital gains, or passive income.

US citizens, and other individuals subject to worldwide residence-based taxation (including taxpayers from countries without full territorial tax systems), should obtain specialist advice from advisers experienced in both Italian tax and their home-country obligations before relying on any estimate of net tax efficiency under art. 24-bis.

HNWI investors evaluating European residence often compare Italy art. 24-bis, Portugal's IFICI regime, and Malta's special tax schemes. The table below provides a framework-level overview based on official sources; it is not personal tax advice and should not be used as the basis for individual tax decisions without specialist review. Figures are jurisdiction-level rules sourced from the official publications cited; they are not guarantees of any tax outcome.

Notes on Malta: The Malta High Net Worth Individuals Rules for EU/EEA/Swiss nationals and for non-EU/EEA/Swiss nationals remain on the statute. Prospective applicants should contact the Malta Tax and Customs Administration (MTCA) directly to confirm whether the scheme is currently accepting applications before taking any reliance on it.

This comparison is for general informational purposes as of June 2026. It does not rank jurisdictions or recommend one programme over another. Individual outcomes depend on personal circumstances, prior tax positions, and professional advice.

If you are looking at the Italy Golden Visa as your route to Italian residence, the art. 24-bis flat-tax election is a related but separate decision: the investor visa establishes your right to reside in Italy, and the tax election — made once you have become an Italian tax resident — determines how your foreign income is taxed. Most HNWI investors plan both steps in sequence with specialist advice rather than treating them as a single question.

My Golden Visa lawyers advise on:

• Italy Golden Visa guide — the investor visa route for non-EU nationals seeking Italian residence
• Italy Golden Visa programme page — eligibility, investment routes, and application process
• European Golden Visa programmes compared — side-by-side overview of EU residence-by-investment options

Contact My Golden Visa lawyers for an initial consultation on Italian tax residence planning and the art. 24-bis election.