Italy · Tax regime
Impatriate Workers Regime (Lavoratori Impatriati)
Cut back sharply by Legislative Decree No. 209/2023 for transfers from 2024 onward: the old 70–90% exemption with a possible 10-year run was replaced by a 50% exemption on income up to EUR 600,000, for 5 years. Unchanged through 2025 and 2026.
This one mostly does not apply to a UHNW principal. It relieves Italian earned income, not foreign investment income, so it does nothing for a portfolio. Its real use in a family plan is for the next generation. An adult child taking an Italian executive role can stack the impatriate relief on their salary while the principal sits under Article 24-bis. Note that the two regimes are mutually exclusive for the same person.
Qualifying routes
50% of qualifying Italian-source employment or self-employment income up to EUR 600,000 is excluded from the tax base.
The exemption rises to 60% if you relocate with a minor child, or have or adopt a child during the benefit period.
The facts
- Minimum
- €600k
- Total landed cost
- There is no cost. This is a relief, not a charge. It can be worth up to roughly EUR 140k a year in tax saved at the top rate on EUR 600k of income.
- Route type
- Tax regime, not a visa
- Physical presence
- You must hold Italian tax residence, and the work itself must be carried out mainly in Italy.
- Family
- The relief applies to the individual worker. The enhanced 60% rate depends on the worker's own minor child
- Permanent residency
- Not applicable. This is a tax relief, not a residency route.
- Citizenship
- Not applicable
- Language test
- Not applicable
- Dual citizenship
- Permitted
- Requirements
- Transfer of tax residence to Italy.Not tax resident in Italy for the 3 preceding tax periods (6 if previously employed in Italy by the same employer or group).Commitment to remain Italian tax resident for at least 4 years.Work performed mainly within Italy.High qualification or specialisation requirements apply.
- Only Italian-source employment and self-employment income qualifies. Foreign investment income, dividends and gains get nothing.
- The EUR 600,000 cap means income above it is fully taxed at ~47.2%.
- A binding four-year Italian tax residence commitment attaches. Leave early and the relief is clawed back with interest.
- Three years of prior non-residence is the baseline, but it rises to six years if you previously worked in Italy for the same employer or group. This rule catches returning secondees.
- The relief runs 5 years only, with no extension mechanism. The old 5+5 arrangement with property purchase or children is gone for post-2024 arrivals.
- Cannot be combined with Article 24-bis for the same individual.