The special tax regime for impatriate workers was incorporated in the Italian tax rules in 2015 to encourage highly qualified and specialised workers to move to Italy and foster at the same time the country’s technological, scientific and cultural development (Art. 16, Law Decree N. 147 of 14th September 2015).
Further on, Law Decree N. 34 of 30th April 2019 changed the features of the above special regime, increasing the envisaged tax benefits and enlarging the field of application. To access the special tax regime, impatriate workers were not required anymore to be high level managers or to be highly qualified.
The new special tax regime for impatriate workers
However, Law Decree N. 209 of 27th December 2023, published in the Official Journal N. 301 of the following 28th December, substantially redefines the special tax regime for impatriate workers.
The “new preferential tax regime for impatriate workers” can be applied to workers moving their fiscal residence to Italy from year 2024 (Art 5 of the above Law Decree N. 209/2023).
On the other hand, the previous rules under Article 16 of Law Decree N. 147 of 14 September 2015 continue to apply, subject to their eligibility requirements, to individuals who transferred their registered residence to Italy by 31 December 2023. For sports employment relationships, the transitional protection applies where the relevant contract was entered into by that date.
From 1 January 2027, the rules currently set out in Article 5 of Legislative Decree No. 209/2023 will be incorporated into Article 225 of the new Income Tax Consolidation Act approved by Legislative Decree No. 117/2026. The decree entered into force on 4 July 2026, but the new consolidated provisions apply from 2027. The eligibility requirements described below therefore continue to be assessed under the provisions applicable to the relevant tax year.
For individuals transferring their tax residence to Italy from the 2027 tax year, the new impatriate relief cannot be combined with the optional flat-tax regime for foreign-source income currently governed by Article 24-bis TUIR. The statutory commencement rule refers specifically to transfers from 2027; this new restriction does not automatically apply to workers who transferred their tax residence earlier.
Differences between the old and the new impatriate tax regime
See below an overall scheme of requirements for the benefits’ application:
| Old impatriates’ regime As per Art. 16, Law Decree 147/2015 In force from 21/05/2022 to 29/12/2023 |
New impatriates’ regime As per Art. 5, Law Decree 209/2023 In force as of 29/12/2023 |
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| Years of residence abroad | 2 tax periods | – 3 tax periods – 6 or 7 tax periods if the work is performed in favour of the same employer, whether resident in Italy or abroad, or another entity in the same group, as defined in Article 5(2). The six- or seven-tax-period requirement depends on the worker’s previous employment history in Italy. |
| Years of residence in Italy (minimum required) | 2 years | 4 years |
| Income eligible for tax relief | – Employment income and assimilated work – Self employment income – Business income for sole proprietors |
– Employment income and assimilated work – Self employment income from practising arts and professional activities |
| Maximum income eligible | None | Annual relief cap of €600,000 of eligible income. Income above this amount remains taxable under the ordinary rules; exceeding the cap does not, by itself, disqualify the worker. |
| Tax benefit | – Taxable Income: 30% – Taxable Income: 10% for impatriates moving to Southern Italy Areas – Taxable Income for Athletes: 50% |
– Taxable Income: 50% – Taxable Income: 40% where the worker relocates with a minor child or a child is born or a minor is adopted during the benefit period, provided that the child is resident in Italy. Fiscal dependency is not required. |
| Benefits’ Duration (years) | – 5 tax years – 5 + 5 tax years if: at least one dependent child or under 18 child or having purchased a real estate property from one year before moving to Italy or after moving to Italy, by the end of the 5 year benefits’ period. |
– 5 tax years – 5 + 3 tax years if registered as a local resident in 2024 and having purchased a real estate property as a main residence by 31/12/2023 |
| Working activity performed in Italy | – Not necessarily for a different employer from before (only exception being the secondment) – Working activity must be performed in Italy for the major part of the tax year (i.e. more than 183 days/year) |
– Working activity can be performed in favour of the same foreign employer or in favour of a company belonging to the same corporation – Working activity must be performed in Italy for the major part of the tax year (i.e. more than 183 days/year). |
| Professional qualification or specialization required | None | High professional qualification or specialization, or previous research, including applied research, in artificial intelligence technologies under the amendment effective from 10 October 2025. |
The Italian Revenue Agency has confirmed that qualifying individuals who moved to Italy between 30 April and 2 July 2019 may also access the additional five-year period under the former regime. The extension runs immediately after the initial five-year period.
New requirements for impatriate workers
Eligible employment income, income assimilated to employment income and self-employment income from arts and professions produced in Italy by workers transferring their tax residence under Article 2 TUIR are included in total taxable income at 50%, up to an aggregate annual amount of €600,000, subject to the conditions below. Any eligible income above that cap remains fully taxable under the ordinary rules. The reduced taxable share of 40% may apply in the cases involving children described below.
Tax residence in Italy for at least four years
The impatriate workers must be committed to keep their tax residence in Italy for at least four years.
In case impatriates moves their tax residency to another country before four years have elapsed, they will lose all the tax benefits and the Tax Agency will proceed to claim back the tax benefits unduly enjoyed, applying the relevant interests on arrears.
Tax residence abroad in the previous three tax years
The impatriate worker must not have been fiscally resident in Italy in the three tax years prior to their relocation.
In case impatriates perform their working activity in Italy in favour of the same employer as before the relocation, or in favour of a company belonging to the same corporation, the minimum required time spent abroad is as follows:
- Six tax years , in case the impatriate had not been employed in Italy by the same employer or by a company belonging to the same corporation before moving abroad;
- Seven tax years, in case the impatriate had been employed in Italy by the same employer or by a company belonging to the same corporation before moving abroad.
The six- or seven-tax-period requirement can also apply when the worker returns as a self-employed professional and provides services to the former employer or its group. A change in contractual status does not, by itself, remove the extended foreign-residence requirement.
The new special tax regime (as the previous regime also did) clearly allows the scheme to be applied in favour of Italian citizens not enlisted in the Registry of Italian citizens resident abroad (AIRE), provided they can prove their previous residence in a foreign country, as provided for by a relevant International Double Taxation Convention.
Work activity and types of income
- Work activities must be performed on the Italian territory for most of the relevant tax period. Remote work performed from Italy for an employer established abroad may qualify, provided that the activity is carried out predominantly in Italy and all the other requirements, including the applicable prior foreign-residence period, are satisfied.
- The impatriate worker is highly qualified or specialised as defined by Law Decree N. 108 of 28th June 2012 and Law Decree N.206 of 9th November 2007.
- The tax benefits are applicable to the following incomes (also included in the previous regime):
- Employment income
- Income from work assimilated to employment income
- Self-employment icome from practicing arts and professional activities
60% tax benefit for impatriate workers
An increased tax benefit of 60% is provided for when:
- The impatriate relocates to Italy with at least one child under 18. The child does not have to be fiscally dependent;
- A new child is born to or adopted by the impatriate during the years of the favourable tax regime; the additional benefit is granted starting from the tax year when the birth/adoption occurred and applies to the remaining years of availability of the tax regime.
Furthermore, the additional benefit can be applied only provided that the child under 18 or the adopted child does live and has residence in Italy. The Italian Revenue Agency has clarified that both parents may claim the increased relief if each meets the conditions. The child reaching the age of 18 after the worker’s relocation does not, by itself, end the increased relief. The 40% taxable share may also apply where the minor children moved to Italy before the worker, provided they remain resident in Italy during the relief period.
Duration and extension of the impatriate tax regime Italy
The tax benefit envisaged by the new impatriates’ regime applies to the income of the tax year in which the tax residence has been relocated to Italy and to the following four tax years. Therefore, the ordinary duration of the tax benefit is of five tax years all together (no changes vis-a-vis the previous law).
Finally, the new rules do not envisage the opportunity to extend further the ordinary duration of the tax benefit.
The only exception to this rule is the one applicable for another three years to impatriates who meet the following conditions:
- The workers moved their registered residence to Italy in the year 2024 and
- Have purchased a residential real estate by 31.12.2023 and, in any event, in the 12 months preceding the relocation to Italy. The real estate must be their main residence in the country.
The tax benefit is subject to the applicable EU de minimis State aid rules. These limits are particularly relevant to self-employed individuals and professionals, rather than employees. Under the general EU Regulation (EU) 2023/2831, the total amount of de minimis aid granted by a Member State to a single undertaking must not exceed €300,000 over any rolling three-year period. This threshold refers to the value of the tax benefit and other relevant aid, not to the annual €600,000 income ceiling under the impatriate regime. Separate rules apply to the agricultural and fisheries sectors.