Italy

The Article 24-bis substitute tax is now EUR 300,000 a year on all foreign-source income, plus EUR 50,000 per family member, for up to 15 years, for individuals transferring legal residence from 1 January 2026. It has been raised twice in eighteen months. It started at EUR 100,000, then doubled to EUR 200,000 by Law Decree No. 113 of 9 August 2024. The 2026 Budget Law, approved on 30 December 2025, then raised it again to EUR 300,000, with the family charge rising from EUR 25,000 to EUR 50,000. A family of four entering in 2026 pays EUR 450,000 a year. Over the full term, that is EUR 6.75m, with no qualifying investment required. The lesson is clear. The rate is now a political variable, not a fixed term. Nothing binds Parliament for your 15 years, so you should model a further increase.

Yes, and grandfathering depends on when you transferred residence, not when you filed. Those who elected in 2024 keep the EUR 100,000 a year rate. Those who were resident by 31 December 2025 keep EUR 200,000. Only transfers from 1 January 2026 pay EUR 300,000. Both earlier cohorts also keep the EUR 25,000 per-family-member charge, rather than the new EUR 50,000. The cut-off is that precise. Moving civil residence by 31 December 2025 versus a day later can be worth EUR 100,000 a year for up to 15 years. Anyone already grandfathered should think hard before doing anything that breaks the election.

Almost certainly not anymore. Decree-Law No. 36/2025 took effect overnight on 27–28 March 2025 and was converted into Law No. 74/2025, effective 24 May 2025. Before this, Italy had no generational limit at all, the most open descent regime in the world. Now it has a hard two-generation limit. Broadly, you need a parent or grandparent born in Italy. Great-grandparent lines no longer qualify. Applications submitted, or consular appointments confirmed, by 23:59 Rome time on 27 March 2025 are assessed under the old, unlimited rules. These are extremely valuable. Everyone else falls under the new ceiling. The Constitutional Court dismissed challenges on 12 March 2026, ruling them partly unfounded and partly inadmissible. The reform stands, and litigation premised on unconstitutionality should be regarded as dead. An estimated 60–80 million people lost a claim overnight.

There is no minimum stay to hold or renew the investor permit. But the permit lapses if you are outside Italy for more than 12 consecutive months, and zero presence forecloses both permanent residence and citizenship. Permanent residence needs five years of legal and actual residence, with an A2 Italian test. Naturalisation needs ten years of legal residence plus B1 Italian, one of the longest routes in the EU. So the visa's zero-presence flexibility and any citizenship ambition do not mix. This is a residence and lifestyle instrument, not a passport play. Its genuinely unusual strength is the approval-first structure. The Nulla Osta clearance is issued before any capital moves, with thresholds running from EUR 250,000 for an innovative start-up to EUR 2m in government bonds. That means your pre-approval financial exposure is close to nil, the reverse of Greece, Malta and Cyprus.

Under Article 24-ter, a foreign pensioner who transfers residence to a qualifying southern municipality pays a 7% substitute tax on all foreign-source income, not just the pension, for up to 10 years. There is no lump sum and no investment required. Law No. 34 of 11 March 2026 expanded the regime, effective 7 April 2026, by raising the municipal population ceiling from 20,000 to 30,000. That change brought 74 previously excluded municipalities into scope. The geography is the whole constraint. The comune must have under 30,000 residents and sit in Sicily, Calabria, Sardinia, Campania, Basilicata, Abruzzo, Molise or Puglia, or a designated earthquake-affected central municipality. Milan, Rome and Florence are not options, and this regime genuinely requires you to live there. You also need a genuine foreign pension, five years of prior non-residence, and a former country with an administrative cooperation agreement with Italy.

The 7% Article 24-ter regime beats the EUR 300,000 Article 24-bis flat tax outright below roughly EUR 4.3m of annual foreign income. That is because 7% is a rate applied to everything, rather than a fixed floor. So a retired principal with a large portfolio, living in a qualifying southern town, can pay 7% on the lot, against EUR 300,000 under 24-bis. The trade-offs: 24-ter runs for only 10 years against 15 for 24-bis, it requires a genuine foreign pension, and it ties you to a small municipality in the Mezzogiorno rather than a major city. Because 7% is a rate, not a cap, at very large foreign income 24-bis eventually wins. Model the crossover before committing to a purchase, and confirm your specific comune qualifies under Law 34/2026.

Italy is not territorial, so an ordinary resident faces roughly a 47.2% effective top rate on worldwide income once regional and municipal surcharges are added, plus IVIE on foreign real estate and IVAFE on foreign financial assets. But there is no domestic wealth tax, and inheritance tax is among the lowest in Western Europe. It runs 4% for a spouse and direct descendants above a EUR 1m per-heir allowance, 6% for siblings, and 8% for others. Under the Article 24-bis flat tax, IVIE and IVAFE are disapplied, and foreign assets sit outside Italian succession and gift tax for the regime's duration. For a family with a nine-figure estate, that can dwarf the annual charge. It is the real reason to choose Italy over cheaper Greece. Italy also applies CFC rules and an exit tax, and the flat tax does not switch these off for corporate structures.

No. No work of any kind is allowed, including remote work for a foreign employer, and this rule is enforced. It is the most common cause of refusal and non-renewal. The Elective Residence Visa is a passive-income route. You must show substantial, stable foreign income, such as pensions, dividends, rents or annuities, with a statutory floor of about EUR 31,000–32,000 for a single applicant and EUR 38,000 for a couple. In practice, consulates routinely expect multiples of that figure and a two-to-three-year track record. A semi-retired principal still taking board fees or consulting income is not eligible. You must also secure Italian accommodation, owned or leased for at least a year in your name, before the visa is granted. That means committing to Italian property before you know you have the visa. And becoming Italian tax resident without electing 24-bis or 24-ter exposes worldwide income at around 47.2%.