Tax relief for inpatriate workers: individuals returning after being posted abroad

The Revenue Agency confirms the implementation measures of the concessions for inpatriates returning from secondments abroad.

Following a recent Italian Revenue Agency consultation and as specified in the Circolare 33/E published on 28/12/2020, the Revenue Agency confirms the non-applicability of the tax relief for the inpatriate workers, who return to Italy after being posted abroad, in the event that:

• The posted worker returns to Italy and is employed by the same employer and under the same employment contract;
• Although there is a new employment contract for a new business role at the time of the repatriation, it is in a situation of continuity with the previous Italian employment position before the expatriation.

Cases of Applicability

Otherwise, the inpatriate tax benefit can be applied if:

• The inpatriate employment activity constitutes a new work activity and the employee, under a new employment contract, assumes a different business role from the one provided for in the contract prior to the posting.