The Internal Revenue Agency has recently offered new clarifications on the special tax regime for impatriate workers, introduced by art. 5 of Legislative Decree 209/2023. The four Rulings, issued on March 12th, 2025, provide details on the qualification requirements, on the minimum duration of residence abroad and on the conditions for those moving to Italy for the first time.
Qualification and specialization – Details from Rulings No. 71/2025 and 74/2025
In order to benefit from the facilitation scheme provided for impatriate workers, it is necessary to possess a high-level qualification or specialization, as described in Legislative Decrees No. 108/2012 and 206/2007. Rulings 71/2025 and 74/2025 specified that such requirements may be satisfied in different ways:
Higher education qualification: Possession of a tertiary-level higher education qualification, issued by the competent authority in the country where it was obtained. Such document must certify the completion of a higher education career of at least 3 years’ duration;
Post-secondary professional qualification: Possession of a post-secondary professional qualification of at least 3 years’ duration, or corresponding to at least level 6 of the National Qualification Framework, as defined by the Decree of the Ministry of Labour and Social Policies from January 8th, 2018;
Requirements of regulated professions: Possession of the requirements indicated in Legislative Decree No. 206/2007, limited to the practice of regulated professions.
- Qualified professional experience: Possession of at least 5 years of experience at a level at least comparable to tertiary degree, consistent with the field of work.
- Experience in ICT: For managers and specialists in the field of information and communication technology (ISCO-08 classifications, No. 133 and 25), a higher professional qualification attested by at least 3 years of relevant professional experience, acquired within the 7 years preceding the submission, is required.
The Internal Revenue Agency has reiterated that qualified work experience may be sufficient to qualify for the impatriate tax regime, even in the absence of an academic degree. Nonetheless, the assessment of these requirements is not within the competence of the Internal Revenue Service itself, due to its technical nature. Therefore, it is up to the taxpayer to obtain recognition of their qualification from the relevant bodies, before being eligible for the facilitation scheme.
Extension of the minimum period of stay abroad – Ruling No. 72/2025
With the enactment of Legislative Decree 209/2023, relevant modifications to the impatriate tax regime have been introduced. One of the main changes regards the extension of the minimum period of tax residence abroad required to access the benefits. Previously, art. 16 of Legislative Decree 147/2015 stated that the worker had to have been fiscally resident abroad in the 2 years prior to the relocation. According to the new dispositions, such requirement has been extended to 3 tax periods. Furthermore, stricter criteria have been introduced for those who worked for the same employer (or for a company of the same group), both before and after the transfer abroad. More specifically, the new requirements refer to a minimum period of stay abroad of:
- 6 years, if the worker had no previous employment relationship with the same company (or group) before the transfer;
- 7 years, if the worker had already been employed for the same company (or group) before the experience abroad.
Implications for self-employed workers: It is important to note that the extension of the minimum period of residence abroad also applies to the self-employed. Hence, a professional who worked abroad for a company and, after returning to Italy, maintains their business relationship with the same company (or group), must have resided abroad for at least six or seven years, depending on the case, in order to benefit from the special regime.
The case of those moving to Italy for the first time – Ruling No. 70/2025
Ruling 70/2025 deals with the case of a foreign citizen moving to Italy for the first time to start a consulting business. The Agency has clarified that the impatriate tax regime is also available to those moving to Italy for the first time, provided that the following requirements are met:
- Commitment to reside in Italy for at least 6 years;
- Possession of high qualification or specialization requirements;
- Performance of the working activity mainly in Italy.
Conclusions
Recent interpretations provided by the Internal Revenue Agency have clarified the access criteria for the impatriate regime, highlighting the legal complexity and the need for a case-by-case approach. Relying on experts may prove decisive in obtaining the expected benefits. Studio Arletti & Partners, with its established experience in this field, provides specialized advice for companies and individuals, guaranteeing a comprehensive support in every stage of the process.
