Italy · Tax regime
Substitute Tax for New Residents (Article 24-bis TUIR)
This charge has gone up twice in 18 months. It started at EUR 100,000. Article 2 of Law Decree No. 113 of 9 August 2024 doubled it to EUR 200,000 for anyone transferring residence from 10 August 2024. The 2026 Budget Law, approved 30 December 2025, raised it again to EUR 300,000 for individuals transferring legal residence from 1 January 2026. The family member charge rose too, from EUR 25,000 to EUR 50,000. Existing cohorts keep their entry rate. Those who elected in 2024 still pay EUR 100,000, and those resident by 31 December 2025 still pay EUR 200,000.
Tripling the entry price in eighteen months is the real story here. Italy has decided this regime is for the genuinely enormous balance sheet, and it is content to lose everyone else. At EUR 300,000 plus EUR 50,000 per head, the cost is now roughly three times Greece's EUR 100,000 plus EUR 20,000, for a comparable Mediterranean life. What Italy still offers that Greece does not is the inheritance tax shelter. Foreign assets sit outside Italian succession tax for the duration of the regime, and for a family with a nine-figure estate, that can dwarf the annual charge.
Qualifying routes
A flat annual tax that replaces ordinary tax on all foreign-source income.
Raised from EUR 25,000.
For those resident by 31 December 2025, the family member charge stays at EUR 25,000.
For those who elected in 2024, the family member charge stays at EUR 25,000.
The facts
- Minimum
- €300k
- Total landed cost
- The principal pays EUR 300,000 a year, plus EUR 50,000 for each family member, for up to 15 years. A family of four entering in 2026 would pay EUR 450,000 annually, EUR 6.75m over the full term. No qualifying investment is required.
- Route type
- Tax regime, not a visa
- Physical presence
- You need Italian tax residence. That means more than 183 days in the country, or a habitual abode or registered residence under Article 43 of the Civil Code.
- Family
- SpouseChildrenParentsSiblings and other defined relatives qualify too, each at EUR 50,000
- Permanent residency
- Not applicable. This is a tax regime layered on top of an immigration status.
- Citizenship
- Not applicable directly, but years of legal residence count toward the 10-year naturalisation requirement.
- Language test
- B1-level Italian is required for naturalisation.
- Dual citizenship
- Permitted
- Requirements
- Transfer your tax residence to Italy.You must not have been tax resident in Italy for at least 9 of the 10 years before the transfer.Make the election in your tax return. You can also request an advance ruling from the Agenzia delle Entrate, though this is optional.Pay EUR 300,000 (2026 cohort) each year by the ordinary income tax deadline.Add EUR 50,000 for each additional family member included.
- The rate has moved twice already. Assume it can move again. This is now demonstrably a political variable, not a fixed term, and nothing in the regime binds Parliament for the full 15 years. Model a further increase.
- Grandfathering attaches to when you transferred residence, not when you filed. Anyone who moved civil residence by 31 December 2025 keeps the EUR 200,000 rate. A day later, and it costs EUR 100,000 a year for up to 15 years.
- Italian-source income sits entirely outside the regime and is taxed at up to ~47.2%.
- Capital gains on qualified shareholdings are excluded from the substitute tax for the first five years. It is a well-known trap for founders planning an exit shortly after arrival.
- Foreign tax credits are not available against the substitute tax. Foreign withholding is pure leakage.
- You can choose to leave certain jurisdictions out of the regime, but that choice is irrevocable for those states. Once you do, that income falls back under full Italian tax and under IVIE/IVAFE.
- Italy still applies CFC rules and an exit tax. The regime does not switch these off for corporate structures.
- There is a hard 15-year limit with no renewal. Revocation for non-payment applies retrospectively.